30%

results/IMAGES003/DOJ-OGR-00007352.json

@@ -0,0 +1,96 @@
+{
+  "document_metadata": {
+    "page_number": "1 of 2",
+    "document_number": "477",
+    "date": "11/19/21",
+    "document_type": "Court Order",
+    "has_handwriting": false,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 477 Filed 11/19/21 Page 1 of 2\nUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK\nUnited States of America,\n-v-\nGhislainc Maxwell,\nDefendant.\nALISON J. NATHAN, District Judge:\nOn October 29, 2021, Defendant filed a motion in limine \"to exclude evidence related to Accuser-3.\" Dkt. Nos. 387, 444. The Court twice heard argument related to this motion, including extensive argument at the November 10, 2021 in camera hearing that was sealed pursuant to Federal Rule of Evidence 412. See generally Nov. 1, 2021 Transcript; Nov. 10, 2021 Transcript. The Court has also considered supplemental briefing from the parties. That briefing has been filed temporarily under seal to permit the parties the opportunity to propose redactions in accordance with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).\nIn a Memorandum Opinion & Order filed under temporary seal, the Court GRANTS in part and DENIES in part the Defendant's motion. The Memorandum Opinion & Order lays out the permissible and impermissible testimony that may be offered by this witness based on Rules 412, 404, 401, and 403.\nThe Court will send the temporarily sealed Memorandum Opinion & Order to the parties.\nBy November 21, 2021, the parties are ORDERED to inform the Court whether either seeks sealing or limited redactions of the Court's Memorandum Opinion & Order and of the supplemental briefing, justifying any such request by reference to Federal Rule of Evidence\nUSDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 11/19/21\n20-CR-330 (AJN)\nORDER\nDOJ-OGR-00007352",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 477 Filed 11/19/21 Page 1 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "United States of America,\n-v-\nGhislainc Maxwell,\nDefendant.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN, District Judge:",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "On October 29, 2021, Defendant filed a motion in limine \"to exclude evidence related to Accuser-3.\" Dkt. Nos. 387, 444. The Court twice heard argument related to this motion, including extensive argument at the November 10, 2021 in camera hearing that was sealed pursuant to Federal Rule of Evidence 412. See generally Nov. 1, 2021 Transcript; Nov. 10, 2021 Transcript. The Court has also considered supplemental briefing from the parties. That briefing has been filed temporarily under seal to permit the parties the opportunity to propose redactions in accordance with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "In a Memorandum Opinion & Order filed under temporary seal, the Court GRANTS in part and DENIES in part the Defendant's motion. The Memorandum Opinion & Order lays out the permissible and impermissible testimony that may be offered by this witness based on Rules 412, 404, 401, and 403.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Court will send the temporarily sealed Memorandum Opinion & Order to the parties.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "By November 21, 2021, the parties are ORDERED to inform the Court whether either seeks sealing or limited redactions of the Court's Memorandum Opinion & Order and of the supplemental briefing, justifying any such request by reference to Federal Rule of Evidence",
+      "position": "middle"
+    },
+    {
+      "type": "stamp",
+      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 11/19/21",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "20-CR-330 (AJN)\nORDER",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007352",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislainc Maxwell",
+      "Alison J. Nathan"
+    ],
+    "organizations": [
+      "United States District Court",
+      "United States of America"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "October 29, 2021",
+      "November 10, 2021",
+      "November 1, 2021",
+      "November 21, 2021",
+      "11/19/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 477",
+      "20-CR-330 (AJN)",
+      "Dkt. Nos. 387, 444",
+      "DOJ-OGR-00007352"
+    ]
+  },
+  "additional_notes": "The document appears to be a court order from the United States District Court for the Southern District of New York. It is related to the case of Ghislainc Maxwell and includes references to various court documents and transcripts. The document is stamped with a 'USDC SDNY DOCUMENT ELECTRONICALLY FILED' stamp and includes a handwritten document number."
+}

results/IMAGES003/DOJ-OGR-00007353.json

@@ -0,0 +1,70 @@
+{
+  "document_metadata": {
+    "page_number": "2 of 2",
+    "document_number": "477",
+    "date": "November 19, 2021",
+    "document_type": "Court Document",
+    "has_handwriting": true,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 477 Filed 11/19/21 Page 2 of 2 412(c)(2) and/or the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). SO ORDERED. Dated: November 19, 2021 New York, New York ALISON J. NATHAN United States District Judge",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 477 Filed 11/19/21 Page 2 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "412(c)(2) and/or the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "SO ORDERED.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November 19, 2021 New York, New York",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN United States District Judge",
+      "position": "middle"
+    },
+    {
+      "type": "handwritten",
+      "content": "Alison J. Nathan",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007353",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan"
+    ],
+    "organizations": [
+      "Second Circuit"
+    ],
+    "locations": [
+      "New York",
+      "Onondaga"
+    ],
+    "dates": [
+      "November 19, 2021",
+      "2006"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "477",
+      "DOJ-OGR-00007353"
+    ]
+  },
+  "additional_notes": "The document appears to be a court order signed by Judge Alison J. Nathan. The text is mostly printed, with a handwritten signature. There are no visible stamps or redactions."
+}

results/IMAGES003/DOJ-OGR-00007355.json

@@ -0,0 +1,62 @@
+{
+  "document_metadata": {
+    "page_number": "2 of 3",
+    "document_number": "478",
+    "date": "11/19/21",
+    "document_type": "Court Document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 478 Filed 11/19/21 Page 2 of 3\n\n- Onsite support, maintenance and other measures are provided to ensure the highest levels of security and reliability.\n\n- The network is totally separate from the court's internal network; it is therefore physically impossible for information on the court's existing systems to be accessed or compromised.\n\nCourtroom Connect will make all necessary arrangements with the Court's District Executive office and computer networking personnel.\n\nIf the Court is agreeable to these arrangements, the Government respectfully requests that the Court enter the enclosed proposed order permitting the parties to proceed.\n\nRespectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\n\nBy: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\n\nCc: Defense Counsel (By ECF)",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 478 Filed 11/19/21 Page 2 of 3",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "- Onsite support, maintenance and other measures are provided to ensure the highest levels of security and reliability.\n\n- The network is totally separate from the court's internal network; it is therefore physically impossible for information on the court's existing systems to be accessed or compromised.\n\nCourtroom Connect will make all necessary arrangements with the Court's District Executive office and computer networking personnel.\n\nIf the Court is agreeable to these arrangements, the Government respectfully requests that the Court enter the enclosed proposed order permitting the parties to proceed.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "By: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Cc: Defense Counsel (By ECF)",
+      "position": "bottom"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Damian Williams",
+      "Maurene Comey",
+      "Alison Moe",
+      "Lara Pomerantz",
+      "Andrew Rohrbach"
+    ],
+    "organizations": [
+      "United States Attorney",
+      "Southern District of New York"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "11/19/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "478"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007356.json

@@ -0,0 +1,80 @@
+{
+  "document_metadata": {
+    "page_number": "3 of 3",
+    "document_number": "478",
+    "date": "11/19/21",
+    "document_type": "Court Order",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 478 Filed 11/19/21 Page 3 of 3\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n---------------------------------------------------------------X\nUNITED STATES OF AMERICA :\n- v. - : 20 Cr. 330 (AJN)\nGHISLAINE MAXWELL, :\nDefendant. :\n---------------------------------------------------------------X\nIT IS HEREBY ORDERED THAT Courtroom Connect, a Southern District of New York contracted vendor, may provide the parties in the United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN), with an Internet connectivity feed for the duration of the trial proceedings, set to begin on Monday, November 29, 2021. Courtroom Connect should make proper arrangements with the District Executive Office of the Court and the official court reporter.\nSO ORDERED:\nDated: November __, 2021\nNew York, New York\nHONORABLE ALISON J. NATHAN\nUNITED STATES DISTRICT JUDGE\nDOJ-OGR-00007356",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 478 Filed 11/19/21 Page 3 of 3",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES OF AMERICA :\n- v. - : 20 Cr. 330 (AJN)\nGHISLAINE MAXWELL, :\nDefendant. :",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "IT IS HEREBY ORDERED THAT Courtroom Connect, a Southern District of New York contracted vendor, may provide the parties in the United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN), with an Internet connectivity feed for the duration of the trial proceedings, set to begin on Monday, November 29, 2021. Courtroom Connect should make proper arrangements with the District Executive Office of the Court and the official court reporter.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "SO ORDERED:",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November __, 2021\nNew York, New York",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "HONORABLE ALISON J. NATHAN\nUNITED STATES DISTRICT JUDGE",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007356",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislaine Maxwell",
+      "Alison J. Nathan"
+    ],
+    "organizations": [
+      "UNITED STATES DISTRICT COURT",
+      "SOUTHERN DISTRICT OF NEW YORK",
+      "Courtroom Connect"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 29, 2021",
+      "November __, 2021",
+      "11/19/21"
+    ],
+    "reference_numbers": [
+      "20 Cr. 330 (AJN)",
+      "S2 20 Cr. 330 (AJN)",
+      "1:20-cr-00330-PAE",
+      "Document 478",
+      "DOJ-OGR-00007356"
+    ]
+  },
+  "additional_notes": "The document appears to be a court order from the United States District Court for the Southern District of New York. The document is related to the case United States v. Ghislaine Maxwell. The order allows Courtroom Connect to provide internet connectivity for the trial. The document is signed by Honorable Alison J. Nathan, United States District Judge."
+}

results/IMAGES003/DOJ-OGR-00007358.json

@@ -0,0 +1,80 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "480",
+    "date": "11/21/21",
+    "document_type": "Court Document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 1 of 9\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA\nv.\nGHISLAINE MAXWELL,\nDefendant.\n\nMS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3)\n\nJeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\n\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600\n\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n225 Broadway, Suite 715\nNew York, NY 10007\nPhone: 212-243-1100\n\nAttorneys for Ghislaine Maxwell\n\nDOJ-OGR-00007358",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 1 of 9",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES OF AMERICA\nv.\nGHISLAINE MAXWELL,\nDefendant.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Jeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\n\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600\n\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n225 Broadway, Suite 715\nNew York, NY 10007\nPhone: 212-243-1100",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Attorneys for Ghislaine Maxwell",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007358",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Jeffrey S. Pagliuca",
+      "Laura A. Menninger",
+      "Christian R. Everdell",
+      "Bobbi C. Sternheim",
+      "Ghislaine Maxwell"
+    ],
+    "organizations": [
+      "HADDON, MORGAN & FOREMAN P.C.",
+      "COHEN & GRESSER LLP",
+      "Law Offices of Bobbi C. Sternheim",
+      "UNITED STATES DISTRICT COURT",
+      "UNITED STATES OF AMERICA"
+    ],
+    "locations": [
+      "Denver",
+      "CO",
+      "New York",
+      "NY"
+    ],
+    "dates": [
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 480",
+      "S2 20 Cr. 330 (AJN)",
+      "DOJ-OGR-00007358"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing in a criminal case against Ghislaine Maxwell. The text is clear and legible, with no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007359.json

@@ -0,0 +1,76 @@
+{
+  "document_metadata": {
+    "page_number": "2 of 9",
+    "document_number": "480",
+    "date": "11/21/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 2 of 9\n\nDefendant Ghislaine Maxwell requests that the Court enter an Order authorizing her counsel to issue a subpoena under Federal Rule of Criminal Procedure 17(c) to Jordana H. Feldman, Administrator, Epstein Victim's Compensation Program, for certain items identified in Attachment A to the proposed Subpoena, together attached as Exhibit 1 to this Motion, for the following reasons:\n\nI. Background\n\nOn October 11, 2021, the government began producing 3500 material to the defense.\nThese rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court's assistance in subpoenaing documents submitted by the Accusers and the witnesses for use at trial. The documents should be returned to this Court for an in camera review and, subject to the Court's review, disclosed to the defense to be used for impeachment of the witnesses at trial.\n\nII. Legal Standard\n\nRule 17(c) permits subpoenas compelling the production of \"books, papers, documents, data, or other objects\" prior to trial. Fed. R. Crim. P. 17(c)(1). Most district courts in the Second Circuit, including this Court, apply the analysis set forth in United States v. Nixon, 418 U.S. 683, 699-700 (1974). See United States v. Pena, No. 15-CR-551 (AJN), 2016 WL 8735699, at *1–2 (S.D.N.Y. Feb. 12, 2016). The party requesting the information \"must make a preponderance showing that the materials requested are relevant, specifically identified, admissible, and not otherwise procurable by the exercise of due diligence.\" Id. (quotations and citations omitted).\n\n1\nDOJ-OGR-00007359",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 2 of 9",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Defendant Ghislaine Maxwell requests that the Court enter an Order authorizing her counsel to issue a subpoena under Federal Rule of Criminal Procedure 17(c) to Jordana H. Feldman, Administrator, Epstein Victim's Compensation Program, for certain items identified in Attachment A to the proposed Subpoena, together attached as Exhibit 1 to this Motion, for the following reasons:",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "I. Background",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "On October 11, 2021, the government began producing 3500 material to the defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court's assistance in subpoenaing documents submitted by the Accusers and the witnesses for use at trial. The documents should be returned to this Court for an in camera review and, subject to the Court's review, disclosed to the defense to be used for impeachment of the witnesses at trial.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "II. Legal Standard",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Rule 17(c) permits subpoenas compelling the production of \"books, papers, documents, data, or other objects\" prior to trial. Fed. R. Crim. P. 17(c)(1). Most district courts in the Second Circuit, including this Court, apply the analysis set forth in United States v. Nixon, 418 U.S. 683, 699-700 (1974). See United States v. Pena, No. 15-CR-551 (AJN), 2016 WL 8735699, at *1–2 (S.D.N.Y. Feb. 12, 2016). The party requesting the information \"must make a preponderance showing that the materials requested are relevant, specifically identified, admissible, and not otherwise procurable by the exercise of due diligence.\" Id. (quotations and citations omitted).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007359",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislaine Maxwell",
+      "Jordana H. Feldman"
+    ],
+    "organizations": [
+      "Epstein Victim's Compensation Program"
+    ],
+    "locations": [
+      "S.D.N.Y."
+    ],
+    "dates": [
+      "October 11, 2021",
+      "11/21/21",
+      "Feb. 12, 2016"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 480",
+      "15-CR-551 (AJN)"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 2 of 9."
+}

results/IMAGES003/DOJ-OGR-00007361.json

@@ -0,0 +1,79 @@
+{
+  "document_metadata": {
+    "page_number": "4",
+    "document_number": "480",
+    "date": "11/21/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 4 of 9 and obtain by any means\" individuals who were under the age of 18, including Accuser-4, \"who were then caused to engage in at least one commercial sex act with Jeffrey Epstein.\" (Id. ✗ 27). Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly occurred \"[f]rom at least in or about 2001, up to and including in or about 2004.\" (Id. ✗✗ 23, 27). B. The Accusers and The Epstein Victim Compensation Fund Ms. Maxwell was not mentioned in that lawsuit. Accuser-4 and Witness-3 applied to the Epstein Victim Compensation Fund. All four women chose to accept compensation from the Epstein Victim Fund. In its 3500 disclosures, the government has provided statements from the Accusers indicating The Protocol for receiving compensation is attached as 1 to Attachment A. The Protocol requires a written submission. The claims are evaluated per the Protocol which credits \"[w]hether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney's Office, or other law enforcement agency.\" Accordingly, the Protocol credits claimants who have had charges filed against Epstein or any employee of Epstein. The June 2019 indictment against Epstein did not include the allegations of the four Accusers that are contained in the S2 Indictment charging Ms. Maxwell. Under the terms of the Protocol, the Accusers here, and their civil lawyers, stood to benefit if the prosecution against Ms. Maxwell went forward. The Protocol also rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse against Epstein, or the Estate, which includes any employees or former employees of Epstein. Lawyers for 3 DOJ-OGR-00007361",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 4 of 9",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "and obtain by any means\" individuals who were under the age of 18, including Accuser-4, \"who were then caused to engage in at least one commercial sex act with Jeffrey Epstein.\" (Id. ✗ 27). Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly occurred \"[f]rom at least in or about 2001, up to and including in or about 2004.\" (Id. ✗✗ 23, 27).",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "B. The Accusers and The Epstein Victim Compensation Fund",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Ms. Maxwell was not mentioned in that lawsuit. Accuser-4 and Witness-3 applied to the Epstein Victim Compensation Fund. All four women chose to accept compensation from the Epstein Victim Fund. In its 3500 disclosures, the government has provided statements from the Accusers indicating",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Protocol for receiving compensation is attached as 1 to Attachment A. The Protocol requires a written submission. The claims are evaluated per the Protocol which credits \"[w]hether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney's Office, or other law enforcement agency.\" Accordingly, the Protocol credits claimants who have had charges filed against Epstein or any employee of Epstein. The June 2019 indictment against Epstein did not include the allegations of the four Accusers that are contained in the S2 Indictment charging Ms. Maxwell.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Under the terms of the Protocol, the Accusers here, and their civil lawyers, stood to benefit if the prosecution against Ms. Maxwell went forward. The Protocol also rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse against Epstein, or the Estate, which includes any employees or former employees of Epstein. Lawyers for",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "3",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007361",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Jeffrey Epstein",
+      "Accuser-4",
+      "Witness-3",
+      "Ms. Maxwell"
+    ],
+    "organizations": [
+      "Epstein Victim Compensation Fund",
+      "United States Attorney's Office",
+      "Office of the District Attorney"
+    ],
+    "locations": [],
+    "dates": [
+      "2001",
+      "2004",
+      "June 2019",
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 480",
+      "DOJ-OGR-00007361"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to the case against Ms. Maxwell, with redactions in several places. The text is mostly printed, with no handwritten content visible. The document includes references to other documents and legal proceedings."
+}

results/IMAGES003/DOJ-OGR-00007362.json

@@ -0,0 +1,69 @@
+{
+  "document_metadata": {
+    "page_number": "5",
+    "document_number": "480",
+    "date": "11/21/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 5 of 9 were instrumental in creating and structuring the terms of the Protocol. See 1. Specificity The Protocol establishes a process that all claimants must follow. The \"Claimant\" must submit a \"Claim Form\" with documentation. These claims are then evaluated based on the criteria established in the Protocol. Any deficiencies in the claim are communicated to the Claimant. If a claim is approved, the Administrator sends the Claimant an offer letter and a release. Ms. Maxwell is requesting specific documents identified in the Protocol, including the Claim Form with any supporting documentation, correspondence between the Claimant (or her attorney) and the Administrator, a copy of the check issued to the Claimant, and a copy of the release signed by the Claimant. 2. Admissibility There are no evidentiary impediments to admissibility. The documents are relevant, authentic, and an appropriate evidentiary foundation can be established under many rules of evidence. The Claim Form is a prior statement of the Accusers about the events alleged in the S2 Indictment. The Claim Forms and subsequent communications are admissible impeachment evidence at trial. 3. Relevance As previously stated, Ms. Maxwell was not mentioned in that lawsuit. Accuser-4 and Witness-3 applied to the Epstein Victim Compensation Fund. All four women here chose to accept compensation from the Epstein Victim Fund. In its 3500 disclosures 4 DOJ-OGR-00007362",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 5 of 9",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "were instrumental in creating and structuring the terms of the Protocol. See",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "1. Specificity The Protocol establishes a process that all claimants must follow. The \"Claimant\" must submit a \"Claim Form\" with documentation. These claims are then evaluated based on the criteria established in the Protocol. Any deficiencies in the claim are communicated to the Claimant. If a claim is approved, the Administrator sends the Claimant an offer letter and a release. Ms. Maxwell is requesting specific documents identified in the Protocol, including the Claim Form with any supporting documentation, correspondence between the Claimant (or her attorney) and the Administrator, a copy of the check issued to the Claimant, and a copy of the release signed by the Claimant.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "2. Admissibility There are no evidentiary impediments to admissibility. The documents are relevant, authentic, and an appropriate evidentiary foundation can be established under many rules of evidence. The Claim Form is a prior statement of the Accusers about the events alleged in the S2 Indictment. The Claim Forms and subsequent communications are admissible impeachment evidence at trial.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "3. Relevance As previously stated,",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Ms. Maxwell was not mentioned in that lawsuit. Accuser-4 and Witness-3 applied to the Epstein Victim Compensation Fund. All four women here chose to accept compensation from the Epstein Victim Fund. In its 3500 disclosures",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "4 DOJ-OGR-00007362",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ms. Maxwell",
+      "Accuser-4",
+      "Witness-3"
+    ],
+    "organizations": [
+      "Epstein Victim Compensation Fund",
+      "Epstein Victim Fund"
+    ],
+    "locations": [],
+    "dates": [
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 480",
+      "DOJ-OGR-00007362"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with redactions in several places. The text is mostly clear, but some parts are blacked out."
+}

results/IMAGES003/DOJ-OGR-00007363.json

@@ -0,0 +1,65 @@
+{
+  "document_metadata": {
+    "page_number": "6",
+    "document_number": "480",
+    "date": "11/21/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 6 of 9 the government has provided statements form the Accusers indicating The Protocol for receiving compensation is attached as Exhibit 1 to Attachment A. The Protocol requires a written submission. The claims are evaluated per the Protocol which credits \"[w]hether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney's Office, or other law enforcement agency.\" Accordingly, the Protocol credits claimants who have had charges filed against Epstein or any employee of Epstein. The June 2019 indictment against Epstein did not include the allegations of the four Accusers that are contained in the S2 Indictment charging Ms. Maxwell. Under the terms of the Protocol the Accusers here, and their civil lawyers, stood to benefit if the prosecution against Ms. Maxwell went forward. The Protocol also rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse against Epstein, or the Estate, which includes any employees or former employees of Epstein. Lawyers for The documents sought are obviously relevant -- statements of the Accusers about what they claim happened for purposes of securing a settlement. Similarly, the amount of compensation is also relevant. \"Relevant evidence means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.\" United States v. Malpeso, 115 F.3d 155, 162-63 (2d Cir. 1997) (quoting Fed. R. Evid. 410). 5 DOJ-OGR-00007363",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 6 of 9",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "the government has provided statements form the Accusers indicating",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "The Protocol for receiving compensation is attached as Exhibit 1 to Attachment A. The Protocol requires a written submission. The claims are evaluated per the Protocol which credits \"[w]hether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney's Office, or other law enforcement agency.\" Accordingly, the Protocol credits claimants who have had charges filed against Epstein or any employee of Epstein. The June 2019 indictment against Epstein did not include the allegations of the four Accusers that are contained in the S2 Indictment charging Ms. Maxwell. Under the terms of the Protocol the Accusers here, and their civil lawyers, stood to benefit if the prosecution against Ms. Maxwell went forward. The Protocol also rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse against Epstein, or the Estate, which includes any employees or former employees of Epstein. Lawyers for",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The documents sought are obviously relevant -- statements of the Accusers about what they claim happened for purposes of securing a settlement. Similarly, the amount of compensation is also relevant. \"Relevant evidence means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.\" United States v. Malpeso, 115 F.3d 155, 162-63 (2d Cir. 1997) (quoting Fed. R. Evid. 410).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "5",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007363",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Epstein",
+      "Ms. Maxwell",
+      "Malpeso"
+    ],
+    "organizations": [
+      "Office of the District Attorney",
+      "United States Attorney's Office"
+    ],
+    "locations": [],
+    "dates": [
+      "June 2019",
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 480",
+      "DOJ-OGR-00007363"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly clear, but some parts are blacked out."
+}

results/IMAGES003/DOJ-OGR-00007365.json

@@ -0,0 +1,91 @@
+{
+  "document_metadata": {
+    "page_number": "8 of 9",
+    "document_number": "480",
+    "date": "November 14, 2021",
+    "document_type": "Court Document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 8 of 9\nDated: November 14, 2021\nRespectfully submitted,\ns/ Jeffrey S. Pagliuca\nJeffrey S. Pagliuca (pro hac vice)\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n225 Broadway, Suite 715\nNew York, NY 10007\nPhone: 212-243-1100\nAttorneys for Ghislaine Maxwell\n7\nDOJ-OGR-00007365",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 8 of 9",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November 14, 2021",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "top"
+    },
+    {
+      "type": "signature",
+      "content": "s/ Jeffrey S. Pagliuca",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Jeffrey S. Pagliuca (pro hac vice)\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Christian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Bobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n225 Broadway, Suite 715\nNew York, NY 10007\nPhone: 212-243-1100",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Attorneys for Ghislaine Maxwell",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "7",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007365",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Jeffrey S. Pagliuca",
+      "Laura A. Menninger",
+      "Christian R. Everdell",
+      "Bobbi C. Sternheim",
+      "Ghislaine Maxwell"
+    ],
+    "organizations": [
+      "HADDON, MORGAN & FOREMAN P.C.",
+      "COHEN & GRESSER LLP",
+      "Law Offices of Bobbi C. Sternheim"
+    ],
+    "locations": [
+      "Denver, CO",
+      "New York, NY"
+    ],
+    "dates": [
+      "November 14, 2021",
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 480",
+      "DOJ-OGR-00007365"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a signature block and attorney information. The document is page 8 of 9."
+}

results/IMAGES003/DOJ-OGR-00007366.json

@@ -0,0 +1,69 @@
+{
+  "document_metadata": {
+    "page_number": "9 of 9",
+    "document_number": "480",
+    "date": "11/21/21",
+    "document_type": "Certificate of Service",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 9 of 9 Certificate of Service I hereby certify that on November 14, 2021, I electronically filed the foregoing Ms. Maxwell's Motion for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P 17(c)(3) with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: Alison Moe Maurene Comey Andrew Rohrbach Lara Pomerantz U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 Alison.moe@usdoj.gov Maurene.comey@usdoj.gov Andrew.Rohrbach@usdoj.gov Lara.Pomerantz@usdoj.gov s/ Nicole Simmons DOJ-OGR-00007366",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page 9 of 9",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Certificate of Service",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "I hereby certify that on November 14, 2021, I electronically filed the foregoing Ms. Maxwell's Motion for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P 17(c)(3) with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following:",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Alison Moe Maurene Comey Andrew Rohrbach Lara Pomerantz U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 Alison.moe@usdoj.gov Maurene.comey@usdoj.gov Andrew.Rohrbach@usdoj.gov Lara.Pomerantz@usdoj.gov",
+      "position": "middle"
+    },
+    {
+      "type": "signature",
+      "content": "s/ Nicole Simmons",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007366",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison Moe",
+      "Maurene Comey",
+      "Andrew Rohrbach",
+      "Lara Pomerantz",
+      "Nicole Simmons",
+      "Maxwell"
+    ],
+    "organizations": [
+      "U.S. Attorney's Office, SDNY"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 14, 2021",
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 480",
+      "DOJ-OGR-00007366"
+    ]
+  },
+  "additional_notes": "The document appears to be a Certificate of Service filed in a court case. It is a standard legal document with no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007367.json

@@ -0,0 +1,44 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "480-1",
+    "date": "11/21/21",
+    "document_type": "Exhibit",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 1 of 16 EXHIBIT 1 DOJ-OGR-00007367",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 1 of 16",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "EXHIBIT 1",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007367",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "DOJ"
+    ],
+    "locations": [],
+    "dates": [
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "480-1",
+      "DOJ-OGR-00007367"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear header and footer. The main content is labeled as 'EXHIBIT 1'."
+}

results/IMAGES003/DOJ-OGR-00007369.json

@@ -0,0 +1,60 @@
+{
+  "document_metadata": {
+    "page_number": "3",
+    "document_number": "480-1",
+    "date": "11/21/21",
+    "document_type": "Subpoena to Produce Documents, Information, or Objects in a Criminal Case",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 3 of 16\nAO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)\nCase No. 20CR330 (AJN)\nPROOF OF SERVICE\nThis subpoena for (name of individual and title, if any)\nwas received by me on (date)\nI served the subpoena by delivering a copy to the named person as follows:\non (date) ; or\nI returned the subpoena unexecuted because:\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of $\nMy fees are $ for travel and $ for services, for a total of $ 0.00 .\nI declare under penalty of perjury that this information is true.\nDate: Server's signature\nPrinted name and title\nServer's address\nAdditional information regarding attempted service, etc.:\nPrint Save As... Add Attachment Reset DOJ-OGR-00007369",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 3 of 16",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Case No. 20CR330 (AJN)",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "PROOF OF SERVICE",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "This subpoena for (name of individual and title, if any)\nwas received by me on (date)\nI served the subpoena by delivering a copy to the named person as follows:\non (date) ; or\nI returned the subpoena unexecuted because:\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of $\nMy fees are $ for travel and $ for services, for a total of $ 0.00 .\nI declare under penalty of perjury that this information is true.\nDate: Server's signature\nPrinted name and title\nServer's address\nAdditional information regarding attempted service, etc.:",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Print Save As... Add Attachment Reset DOJ-OGR-00007369",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "United States"
+    ],
+    "locations": [],
+    "dates": [
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "20CR330",
+      "480-1",
+      "DOJ-OGR-00007369"
+    ]
+  },
+  "additional_notes": "The document is a proof of service form for a subpoena in a criminal case. It is page 3 of 16 and was filed on 11/21/21. The form is mostly blank, with some printed text and a total fee amount of $0.00 handwritten."
+}

results/IMAGES003/DOJ-OGR-00007372.json

@@ -0,0 +1,54 @@
+{
+  "document_metadata": {
+    "page_number": "6",
+    "document_number": "480-1",
+    "date": "11/21/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 6 of 16 become aware of any further information, Documents, things, or information responsive to this Request, you are required to so state by supplementing your responses and producing such additional Documents to Defendant. DOCUMENTS OR THINGS TO BE PRODUCED 1. Any and all EVCP Material submitted by each Accuser, not limited to Claim Forms and supporting submissions made by each Accuser; 2. Communications between the EVCP to each of the Accusers and/ or their Attorneys; 3. Copies of any payments to the Accusers and their Attorneys; 4. Any and All Releases executed by the Accusers. DOJ-OGR-00007372",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 6 of 16",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "become aware of any further information, Documents, things, or information responsive to this Request, you are required to so state by supplementing your responses and producing such additional Documents to Defendant.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "DOCUMENTS OR THINGS TO BE PRODUCED",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1. Any and all EVCP Material submitted by each Accuser, not limited to Claim Forms and supporting submissions made by each Accuser; 2. Communications between the EVCP to each of the Accusers and/ or their Attorneys; 3. Copies of any payments to the Accusers and their Attorneys; 4. Any and All Releases executed by the Accusers.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007372",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "DOJ"
+    ],
+    "locations": [],
+    "dates": [
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "480-1",
+      "DOJ-OGR-00007372"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007373.json

@@ -0,0 +1,44 @@
+{
+  "document_metadata": {
+    "page_number": "7",
+    "document_number": "480-1",
+    "date": "11/21/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 7 of 16 EXHIBIT 1 DOJ-OGR-00007373",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 7 of 16",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "EXHIBIT 1",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007373",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "DOJ"
+    ],
+    "locations": [],
+    "dates": [
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "480-1",
+      "DOJ-OGR-00007373"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear header and footer. The main content is labeled 'EXHIBIT 1'."
+}

results/IMAGES003/DOJ-OGR-00007382.json

@@ -0,0 +1,77 @@
+{
+  "document_metadata": {
+    "page_number": "16 of 16",
+    "document_number": "480-1",
+    "date": "11/21/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 16 of 16 mediation privileges, settlement privileges and other privileges apply. To protect the privacy of Claimants participating in the Program, all personal information provided by the Claimant during this process will be returned or destroyed within one year after the conclusion of the Program. Individual Claimants are not bound through the Program by any rules of confidentiality. Claimants may, at their sole and voluntary option, disclose information in their possession regarding their claim, their compensation and their experience with the Program. All confidentiality requirements are subject to law, regulation and judicial process. E. Reporting The Administrator shall, on a monthly basis, confidentially provide reports regarding the number and total value of claims paid each month to the Probate Court of the United States Virgin Islands and the Attorney General of the United States Virgin Islands. Such reports will report on an aggregate level only. No individual Claimant information will be published or disclosed in a way that compromises Claimant confidentiality. 9|Page DOJ-OGR-00007382",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 16 of 16",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "mediation privileges, settlement privileges and other privileges apply.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "To protect the privacy of Claimants participating in the Program, all personal information provided by the Claimant during this process will be returned or destroyed within one year after the conclusion of the Program.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Individual Claimants are not bound through the Program by any rules of confidentiality. Claimants may, at their sole and voluntary option, disclose information in their possession regarding their claim, their compensation and their experience with the Program.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "All confidentiality requirements are subject to law, regulation and judicial process.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "E. Reporting",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Administrator shall, on a monthly basis, confidentially provide reports regarding the number and total value of claims paid each month to the Probate Court of the United States Virgin Islands and the Attorney General of the United States Virgin Islands. Such reports will report on an aggregate level only. No individual Claimant information will be published or disclosed in a way that compromises Claimant confidentiality.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "9|Page",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007382",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "Probate Court of the United States Virgin Islands",
+      "Attorney General of the United States Virgin Islands"
+    ],
+    "locations": [
+      "United States Virgin Islands"
+    ],
+    "dates": [
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "480-1",
+      "DOJ-OGR-00007382"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to a program for claimants. The text discusses confidentiality and reporting requirements. The document is well-formatted and legible."
+}

results/IMAGES003/DOJ-OGR-00007383.json

@@ -0,0 +1,89 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "481",
+    "date": "November 21, 2021",
+    "document_type": "Letter",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 481 Filed 11/21/21 Page 1 of 2\nU.S Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nNovember 21, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nPursuant to the Court's Order at Dkt. No. 477, the Government is submitting today proposed redactions to the parties' supplemental briefing regarding Witness-3 and the Court's Memorandum Opinion & Order resolving those motions.\nThe Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of Witness-3, who has not identified herself on the record in this case, and who is a subject of the Court's pseudonym order. In addition, some of the proposed redactions reference sealed materials from the Rule 412 litigation, which are \"related materials\" within the meaning of Fed. R. Evid. 412(c)(2).\nDOJ-OGR-00007383",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 481 Filed 11/21/21 Page 1 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "U.S Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "November 21, 2021",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "BY ECF",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan:\nPursuant to the Court's Order at Dkt. No. 477, the Government is submitting today proposed redactions to the parties' supplemental briefing regarding Witness-3 and the Court's Memorandum Opinion & Order resolving those motions.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of Witness-3, who has not identified herself on the record in this case, and who is a subject of the Court's pseudonym order. In addition, some of the proposed redactions reference sealed materials from the Rule 412 litigation, which are \"related materials\" within the meaning of Fed. R. Evid. 412(c)(2).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007383",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ghislaine Maxwell",
+      "Judge Nathan",
+      "Witness-3"
+    ],
+    "organizations": [
+      "U.S Department of Justice",
+      "United States Attorney",
+      "United States District Court",
+      "Second Circuit"
+    ],
+    "locations": [
+      "New York",
+      "Onondaga"
+    ],
+    "dates": [
+      "November 21, 2021",
+      "2006"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 481",
+      "20 Cr. 330 (AJN)",
+      "Dkt. No. 477",
+      "435 F.3d 110",
+      "DOJ-OGR-00007383"
+    ]
+  },
+  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses proposed redactions to certain documents and references relevant legal precedents and rules."
+}

results/IMAGES003/DOJ-OGR-00007384.json

@@ -0,0 +1,73 @@
+{
+  "document_metadata": {
+    "page_number": "2",
+    "document_number": "481",
+    "date": "11/21/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 481 Filed 11/21/21 Page 2 of 2 Page 2 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) DOJ-OGR-00007384",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 481 Filed 11/21/21 Page 2 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "DAMIAN WILLIAMS United States Attorney",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Cc: Defense Counsel (By ECF)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007384",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Damian Williams",
+      "Maurene Comey",
+      "Alison Moe",
+      "Lara Pomerantz",
+      "Andrew Rohrbach"
+    ],
+    "organizations": [
+      "United States Attorney",
+      "Southern District of New York"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "481",
+      "DOJ-OGR-00007384"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a signature block and a cc section. The text is clear and legible."
+}

results/IMAGES003/DOJ-OGR-00007385.json

@@ -0,0 +1,103 @@
+{
+  "document_metadata": {
+    "page_number": "1 of 2",
+    "document_number": "482",
+    "date": "11/21/21",
+    "document_type": "Court Order",
+    "has_handwriting": false,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 482 Filed 11/21/21 Page 1 of 2\nUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK\nUnited States of America,\n-v-\nGhislaine Maxwell,\nDefendant.\nALISON J. NATHAN, District Judge:\nOn November 1, 2021, the Defense noticed eight expert witnesses. Def. Br., Ex. 1 (\"Notice\"). On November 8, 2021, the Government filed a motion to partially preclude the testimony of two of those experts, Dr. Dietz and Dr. Loftus. Gov't Br., Dkt. No. 424. The Defense filed a response via email on November 12, 2021, to permit the Government the opportunity to propose redactions.\nIn an Opinion and Order temporarily filed under seal, the Court DENIES in part and GRANTS in part the Government's motion to preclude Dr. Dietz's testimony and DENIES in part and GRANTS in part the Government's motion to preclude Dr. Loftus's testimony. It does so after considering the admissibility of the anticipated testimony under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993).\nThe Court will send the temporarily sealed Opinion & Order to the parties. By November 23, 2021, the parties are ORDERED to inform the Court whether either seeks sealing or limited redactions of the Court's Opinion & Order, justifying any such request by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). In addition, by that date, the parties are FURTHER ORDERED to file\n1\nDOJ-OGR-00007385",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 482 Filed 11/21/21 Page 1 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "United States of America,\n-v-\nGhislaine Maxwell,\nDefendant.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "20-CR-330 (AJN)\nORDER",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN, District Judge:",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "On November 1, 2021, the Defense noticed eight expert witnesses. Def. Br., Ex. 1 (\"Notice\"). On November 8, 2021, the Government filed a motion to partially preclude the testimony of two of those experts, Dr. Dietz and Dr. Loftus. Gov't Br., Dkt. No. 424. The Defense filed a response via email on November 12, 2021, to permit the Government the opportunity to propose redactions.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "In an Opinion and Order temporarily filed under seal, the Court DENIES in part and GRANTS in part the Government's motion to preclude Dr. Dietz's testimony and DENIES in part and GRANTS in part the Government's motion to preclude Dr. Loftus's testimony. It does so after considering the admissibility of the anticipated testimony under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Court will send the temporarily sealed Opinion & Order to the parties. By November 23, 2021, the parties are ORDERED to inform the Court whether either seeks sealing or limited redactions of the Court's Opinion & Order, justifying any such request by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). In addition, by that date, the parties are FURTHER ORDERED to file",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1",
+      "position": "footer"
+    },
+    {
+      "type": "stamp",
+      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 11/21/21",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007385",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislaine Maxwell",
+      "Alison J. Nathan",
+      "Dr. Dietz",
+      "Dr. Loftus"
+    ],
+    "organizations": [
+      "United States District Court",
+      "United States of America",
+      "Second Circuit"
+    ],
+    "locations": [
+      "New York",
+      "Onondaga"
+    ],
+    "dates": [
+      "November 1, 2021",
+      "November 8, 2021",
+      "November 12, 2021",
+      "November 21, 2021",
+      "November 23, 2021",
+      "1993",
+      "2006"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 482",
+      "20-CR-330 (AJN)",
+      "Dkt. No. 424",
+      "509 U.S. 579",
+      "435 F.3d 110"
+    ]
+  },
+  "additional_notes": "The document is a court order from the United States District Court for the Southern District of New York. It appears to be a formal legal document with proper formatting and language. There are no visible redactions or damage to the document."
+}

results/IMAGES003/DOJ-OGR-00007386.json

@@ -0,0 +1,72 @@
+{
+  "document_metadata": {
+    "page_number": "2",
+    "document_number": "482",
+    "date": "November 21, 2021",
+    "document_type": "Court Document",
+    "has_handwriting": true,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 482 Filed 11/21/21 Page 2 of 2 any proposed redactions to the Defense's response brief and/or supporting exhibits on the public docket, again justifying any such request by reference to the Lugosch test. SO ORDERED. Dated: November 21, 2021 New York, New York ALISON J. NATHAN United States District Judge 2 DOJ-OGR-00007386",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 482 Filed 11/21/21 Page 2 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "any proposed redactions to the Defense's response brief and/or supporting exhibits on the public docket, again justifying any such request by reference to the Lugosch test.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "SO ORDERED.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November 21, 2021 New York, New York",
+      "position": "middle"
+    },
+    {
+      "type": "handwritten",
+      "content": "Alison J. Nathan",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN United States District Judge",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "2",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007386",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan"
+    ],
+    "organizations": [],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 21, 2021",
+      "11/21/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "482",
+      "DOJ-OGR-00007386"
+    ]
+  },
+  "additional_notes": "The document appears to be a court order with a signature from Judge Alison J. Nathan. The document is well-formatted and legible."
+}

results/IMAGES003/DOJ-OGR-00007387.json

@@ -0,0 +1,97 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "483",
+    "date": "11/22/21",
+    "document_type": "Court Order",
+    "has_handwriting": false,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 483 Filed 11/22/21 Page 1 of 2\nUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK\nUnited States of America,\n-v-\nGhislaine Maxwell,\nDefendant.\nALISON J. NATHAN, District Judge:\nAs noted at the November 10 conference, the Court will hold final pretrial conference on November 23, 2021 at 9:30 a.m. The proceeding will take place in Courtroom 318 of the United States District Court for the Southern District of New York, Thurgood Marshall U.S. Courthouse at 40 Foley Square, New York, New York. In accordance with its prior Order, the Court will ensure access for alleged victims and any members of the Defendant's family. Dkt. No. 344.\nIn order to comply with the District's COVID-19 protocols, a number of pool reporters will be permitted in the courtroom proper as managed by the District Executive's Office. In-house press will also be able to access the proceeding in overflow press rooms. The public will be able to access the proceeding in overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse. These overflow rooms will have live video and audio feeds of the proceeding. The use of any electronic devices during the proceeding in the overflow rooms is strictly prohibited.\nThe Court anticipates seating capacity in the overflow rooms for at least 90 members of the public. If capacity is reached, no additional persons will be admitted. Per the S.D.N.Y. Response to COVID-19, anyone who appears at any S.D.N.Y. courthouse must complete a\n1\nDOJ-OGR-00007387",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 483 Filed 11/22/21 Page 1 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "United States of America,\n-v-\nGhislaine Maxwell,\nDefendant.",
+      "position": "top"
+    },
+    {
+      "type": "stamp",
+      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC#: DATE FILED: 11/22/21",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "20-CR-330 (AJN)\nORDER",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN, District Judge:",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "As noted at the November 10 conference, the Court will hold final pretrial conference on November 23, 2021 at 9:30 a.m. The proceeding will take place in Courtroom 318 of the United States District Court for the Southern District of New York, Thurgood Marshall U.S. Courthouse at 40 Foley Square, New York, New York. In accordance with its prior Order, the Court will ensure access for alleged victims and any members of the Defendant's family. Dkt. No. 344.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "In order to comply with the District's COVID-19 protocols, a number of pool reporters will be permitted in the courtroom proper as managed by the District Executive's Office. In-house press will also be able to access the proceeding in overflow press rooms. The public will be able to access the proceeding in overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse. These overflow rooms will have live video and audio feeds of the proceeding. The use of any electronic devices during the proceeding in the overflow rooms is strictly prohibited.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Court anticipates seating capacity in the overflow rooms for at least 90 members of the public. If capacity is reached, no additional persons will be admitted. Per the S.D.N.Y. Response to COVID-19, anyone who appears at any S.D.N.Y. courthouse must complete a",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007387",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislaine Maxwell",
+      "Alison J. Nathan"
+    ],
+    "organizations": [
+      "United States District Court",
+      "Southern District of New York",
+      "District Executive's Office"
+    ],
+    "locations": [
+      "New York",
+      "Thurgood Marshall U.S. Courthouse",
+      "40 Foley Square"
+    ],
+    "dates": [
+      "November 10",
+      "November 23, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 483",
+      "20-CR-330 (AJN)",
+      "Dkt. No. 344",
+      "DOJ-OGR-00007387"
+    ]
+  },
+  "additional_notes": "The document appears to be a court order from the United States District Court for the Southern District of New York. It is related to the case of Ghislaine Maxwell and includes details about a pretrial conference. The document is stamped as being electronically filed on 11/22/21."
+}

results/IMAGES003/DOJ-OGR-00007388.json

@@ -0,0 +1,74 @@
+{
+  "document_metadata": {
+    "page_number": "2 of 2",
+    "document_number": "483",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": true,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 483 Filed 11/22/21 Page 2 of 2\n\nquestionnaire on the date of the proceeding prior to entering the courthouse. All visitors must also have their temperature taken when they arrive at the courthouse. Only persons who meet the entry requirements established by the questionnaire and whose temperatures are below 100.4 degrees will be allowed to enter the courthouse. All visitors must wear a mask that covers the person's nose and mouth. Bandannas, gaiters, and masks with valves are not permitted. If a person does not have an approved mask, a screener will provide one. Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse. There are no exceptions. For more information, please see https://www.nysd.uscourts.gov/covid-19-coronavirus.\n\nSO ORDERED.\n\nDated: November 22, 2021\nNew York, New York\n\nALISON J. NATHAN\nUnited States District Judge\n\n2\nDOJ-OGR-00007388",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 483 Filed 11/22/21 Page 2 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "questionnaire on the date of the proceeding prior to entering the courthouse. All visitors must also have their temperature taken when they arrive at the courthouse. Only persons who meet the entry requirements established by the questionnaire and whose temperatures are below 100.4 degrees will be allowed to enter the courthouse. All visitors must wear a mask that covers the person's nose and mouth. Bandannas, gaiters, and masks with valves are not permitted. If a person does not have an approved mask, a screener will provide one. Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse. There are no exceptions. For more information, please see https://www.nysd.uscourts.gov/covid-19-coronavirus.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "SO ORDERED.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November 22, 2021\nNew York, New York",
+      "position": "middle"
+    },
+    {
+      "type": "signature",
+      "content": "",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN\nUnited States District Judge",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "2",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007388",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "ALISON J. NATHAN"
+    ],
+    "organizations": [
+      "Court"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 22, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "483",
+      "DOJ-OGR-00007388"
+    ]
+  },
+  "additional_notes": "The document appears to be a court order regarding COVID-19 protocols in a courthouse. It is signed by a judge and includes a URL for further information."
+}

results/IMAGES003/DOJ-OGR-00007389.json

@@ -0,0 +1,115 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "41345",
+    "date": "November 19, 2021",
+    "document_type": "Letter",
+    "has_handwriting": true,
+    "has_stamps": true
+  },
+  "full_text": "Case#: 2020cr00303 (AJN Document#: 41345 Filed: 11/22/21 Page#: 1 of 1 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: Pursuant to the Court's email of November 15, 2021, the parties respectfully submit this joint letter to request video monitors with a live feed to the trial proceedings in each of the parties' counsel rooms. The parties have conferred and each side consents to the other's request. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By ECF) USDCDOCSDNY DOCUMENT ELECTRONICALLY FILED DOC#: DATE FILED: 11/22/21 November 19, 2021 To the extent that the Government is requesting that a video monitor be provided in a counsel room at 40 Foley Square, the request is granted to the extent the District Executive can accommodate the request. If the Government is requesting a video monitor in its own offices, the request is denied. The request is granted as to defense counsel's room. SO ORDERED. Alison J. Nathan 11/22/21",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case#: 2020cr00303 (AJN Document#: 41345 Filed: 11/22/21 Page#: 1 of 1",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
+      "position": "left margin"
+    },
+    {
+      "type": "printed",
+      "content": "BY ECF",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan:",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Pursuant to the Court's email of November 15, 2021, the parties respectfully submit this joint letter to request video monitors with a live feed to the trial proceedings in each of the parties' counsel rooms. The parties have conferred and each side consents to the other's request.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Sincerely,",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "/s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "cc: All Counsel of Record (By ECF)",
+      "position": "footer"
+    },
+    {
+      "type": "stamp",
+      "content": "USDCDOCSDNY DOCUMENT ELECTRONICALLY FILED DOC#: DATE FILED: 11/22/21",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "November 19, 2021",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "To the extent that the Government is requesting that a video monitor be provided in a counsel room at 40 Foley Square, the request is granted to the extent the District Executive can accommodate the request. If the Government is requesting a video monitor in its own offices, the request is denied. The request is granted as to defense counsel's room. SO ORDERED.",
+      "position": "body"
+    },
+    {
+      "type": "signature",
+      "content": "Alison J. Nathan 11/22/21",
+      "position": "body"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Christian R. Everdell",
+      "Alison J. Nathan",
+      "Ghislaine Maxwell"
+    ],
+    "organizations": [
+      "COHEN & GRESSER LLP",
+      "United States District Court",
+      "Southern District of New York"
+    ],
+    "locations": [
+      "New York",
+      "40 Foley Square"
+    ],
+    "dates": [
+      "November 19, 2021",
+      "November 15, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "2020cr00303",
+      "S2 20 Cr. 330 (AJN)",
+      "41345"
+    ]
+  },
+  "additional_notes": "The document is a letter from Christian R. Everdell to Judge Alison J. Nathan regarding a request for video monitors in the counsel rooms during the trial of Ghislaine Maxwell. The letter is signed by Christian Everdell and has a stamp indicating that it was electronically filed on November 22, 2021. The document is typed with a signature and a stamp."
+}

results/IMAGES003/DOJ-OGR-00007390.json

@@ -0,0 +1,105 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "485",
+    "date": "11/22/21",
+    "document_type": "Court Order",
+    "has_handwriting": false,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 485 Filed 11/22/21 Page 1 of 1\nUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK\nUnited States of America,\n-v-\nGhislainc Maxwell,\nDefendant.\nALISON J. NATHAN, District Judge:\nThe Court is in receipt of the Government's proposed redactions to the parties' supplemental briefing and the Court's Memorandum Opinion & Order regarding the admissibility of the anticipated testimony of Witness-3. Dkt. No. 481; see also Dkt. No. 477.\nThe Court concludes that the proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and narrowly tailored to protect the pre-trial privacy interests of an anticipated witness who is subject to this Court's pseudonym order. The redactions also properly protect materials related to the Rule 412 motion, which must remain sealed pursuant Rule 412. Fed. R. Evid. 412(c)(2); see also Advisory Committee Note—1994 Amendment.\nAccordingly, the parties are ORDERED to file the redacted papers on the public docket by November 22, 2021, including the Government's supplemental letter regarding Witness-3 dated November 7, 2021 in response to Dkt. No. 417. The Court will file the redacted Memorandum Opinion & Order.\nSO ORDERED.\nDated: November 22, 2021 New York, New York\nALISON J. NATHAN United States District Judge\nUSDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 11/22/21\n20-CR-330 (AJN)\nORDER\nDOJ-OGR-00007390",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 485 Filed 11/22/21 Page 1 of 1",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "United States of America,\n-v-\nGhislainc Maxwell,\nDefendant.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN, District Judge:",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "The Court is in receipt of the Government's proposed redactions to the parties' supplemental briefing and the Court's Memorandum Opinion & Order regarding the admissibility of the anticipated testimony of Witness-3. Dkt. No. 481; see also Dkt. No. 477.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Court concludes that the proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and narrowly tailored to protect the pre-trial privacy interests of an anticipated witness who is subject to this Court's pseudonym order. The redactions also properly protect materials related to the Rule 412 motion, which must remain sealed pursuant Rule 412. Fed. R. Evid. 412(c)(2); see also Advisory Committee Note—1994 Amendment.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Accordingly, the parties are ORDERED to file the redacted papers on the public docket by November 22, 2021, including the Government's supplemental letter regarding Witness-3 dated November 7, 2021 in response to Dkt. No. 417. The Court will file the redacted Memorandum Opinion & Order.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "SO ORDERED.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November 22, 2021 New York, New York",
+      "position": "bottom"
+    },
+    {
+      "type": "signature",
+      "content": "ALISON J. NATHAN United States District Judge",
+      "position": "bottom"
+    },
+    {
+      "type": "stamp",
+      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 11/22/21",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "20-CR-330 (AJN)\nORDER",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007390",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislainc Maxwell",
+      "Alison J. Nathan"
+    ],
+    "organizations": [
+      "United States District Court",
+      "United States of America"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 22, 2021",
+      "November 7, 2021"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 485",
+      "Dkt. No. 481",
+      "Dkt. No. 477",
+      "Dkt. No. 417",
+      "20-CR-330 (AJN)",
+      "DOJ-OGR-00007390"
+    ]
+  },
+  "additional_notes": "The document is a court order with a stamp indicating it was electronically filed. The text is mostly printed, with a signature at the bottom."
+}

results/IMAGES003/DOJ-OGR-00007391.json

@@ -0,0 +1,77 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "486",
+    "date": "11/22/21",
+    "document_type": "Letter",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 Page 1 of 2\nU.S Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nNovember 22, 2021\nBY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nPursuant to the Court's Orders at Dkt. Nos. 473, 474, and 476, the parties are docketing today the Government's motion to quash the defendant's Rule 17(c) subpoena, proposed redacted versions of the Government's letter motion of November 18, 2021 and the defendant's response, and proposed redacted versions of the defendant's response relating to Government Exhibit 52 and the Government's reply.\nThe defense has informed the Government that they are not seeking redactions to these filings.\nThe Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).\nAlthough the parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of the Minor Victims and witnesses, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order.\nDOJ-OGR-00007391",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 Page 1 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "U.S Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "November 22, 2021",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "BY ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan:\nPursuant to the Court's Orders at Dkt. Nos. 473, 474, and 476, the parties are docketing today the Government's motion to quash the defendant's Rule 17(c) subpoena, proposed redacted versions of the Government's letter motion of November 18, 2021 and the defendant's response, and proposed redacted versions of the defendant's response relating to Government Exhibit 52 and the Government's reply.\nThe defense has informed the Government that they are not seeking redactions to these filings.\nThe Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).\nAlthough the parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of the Minor Victims and witnesses, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007391",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ghislaine Maxwell"
+    ],
+    "organizations": [
+      "U.S Department of Justice",
+      "United States Attorney",
+      "United States District Court",
+      "Second Circuit"
+    ],
+    "locations": [
+      "New York",
+      "Southern District of New York",
+      "Onondaga"
+    ],
+    "dates": [
+      "November 22, 2021",
+      "November 18, 2021",
+      "2006"
+    ],
+    "reference_numbers": [
+      "20 Cr. 330 (AJN)",
+      "Dkt. Nos. 473, 474, and 476",
+      "435 F.3d 110",
+      "DOJ-OGR-00007391"
+    ]
+  },
+  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The document is well-formatted and free of significant damage or redactions."
+}

results/IMAGES003/DOJ-OGR-00007392.json

@@ -0,0 +1,73 @@
+{
+  "document_metadata": {
+    "page_number": "2",
+    "document_number": "486",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 Page 2 of 2\nPage 2\nRespectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nBy: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nCc: Defense Counsel (By ECF)\nDOJ-OGR-00007392",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 Page 2 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DAMIAN WILLIAMS\nUnited States Attorney",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "By: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Cc: Defense Counsel (By ECF)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007392",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Damian Williams",
+      "Maurene Comey",
+      "Alison Moe",
+      "Lara Pomerantz",
+      "Andrew Rohrbach"
+    ],
+    "organizations": [
+      "United States Attorney",
+      "Southern District of New York"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "486",
+      "DOJ-OGR-00007392"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a signature block and a cc section. The text is clear and legible."
+}

results/IMAGES003/DOJ-OGR-00007393.json

@@ -0,0 +1,86 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "487",
+    "date": "11/22/21",
+    "document_type": "Letter Motion",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page 1 of 8 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 18, 2021 BY E-MAIL The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter motion to quash the defendant's Rule 17(c)(3) subpoena to Jordana Feldman, the administrator of the Epstein Victims' Compensation Program (EVCP). For the reasons set forth below, the subpoena should be quashed.1 I. Applicable Law As the defendant acknowledges, she bears the burden of satisfying the standard in United States v. Nixon, 418 U.S. 683 (1974). (Def. Mot. at 1). Pursuant to that standard, the \"party seeking issuance of [a Rule 17(c)] subpoena must clear three hurdles: (1) relevancy; (2) admissibility; (3) specificity.\" United States v. Cole, 2021 WL 912425, at *3 (S.D.N.Y. Mar. 10, 2021) (internal quotation marks omitted). The proponent must also establish that the records sought \"are not otherwise procurable.\" Id. (quoting Nixon, 418 U.S. at 699-700). 1 For sake of simplicity, the Government uses the term \"Minor Victims\" to include Witness-3. The Government acknowledges the Court's order that Witness-3 should not be referenced at trial as a victim. DOJ-OGR-00007393",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page 1 of 8",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "U.S. Department of Justice United States Attorney Southern District of New York",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 18, 2021",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "BY E-MAIL",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan: The Government respectfully submits this letter motion to quash the defendant's Rule 17(c)(3) subpoena to Jordana Feldman, the administrator of the Epstein Victims' Compensation Program (EVCP). For the reasons set forth below, the subpoena should be quashed.1 I. Applicable Law As the defendant acknowledges, she bears the burden of satisfying the standard in United States v. Nixon, 418 U.S. 683 (1974). (Def. Mot. at 1). Pursuant to that standard, the \"party seeking issuance of [a Rule 17(c)] subpoena must clear three hurdles: (1) relevancy; (2) admissibility; (3) specificity.\" United States v. Cole, 2021 WL 912425, at *3 (S.D.N.Y. Mar. 10, 2021) (internal quotation marks omitted). The proponent must also establish that the records sought \"are not otherwise procurable.\" Id. (quoting Nixon, 418 U.S. at 699-700).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1 For sake of simplicity, the Government uses the term \"Minor Victims\" to include Witness-3. The Government acknowledges the Court's order that Witness-3 should not be referenced at trial as a victim.",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007393",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ghislaine Maxwell",
+      "Jordana Feldman"
+    ],
+    "organizations": [
+      "U.S. Department of Justice",
+      "United States Attorney",
+      "Southern District of New York",
+      "Epstein Victims' Compensation Program"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 18, 2021",
+      "March 10, 2021",
+      "1974"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 487",
+      "S2 20 Cr. 330 (AJN)",
+      "DOJ-OGR-00007393"
+    ]
+  },
+  "additional_notes": "The document appears to be a formal letter motion filed with the court, with proper formatting and citations. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007396.json

@@ -0,0 +1,54 @@
+{
+  "document_metadata": {
+    "page_number": "4",
+    "document_number": "487",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page 4 of 8\nPage 4\nC. Any and All Material Submitted to the EVCP\nThe defendant makes a further request for any and all submissions by the Minor Victims to the EVCP. This request would not generate relevant, admissible evidence for two reasons.\nFirst, the defendant has not identified a theory by which these materials are relevant and admissible. The defendant argues primarily that the materials contain relevant impeachment information because \"[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others.\" (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by Nixon, simply because they aid the defendant's \"understanding.\" And the defendant articulates only one theory by which EVCP materials may be admitted to show bias. According to the defendant, the May 2020 Protocol governing the EVCP states that claims are evaluated depending on whether \"there exists any information and/or pertinent findings offered by the appropriate . . . United States Attorneys' Office or other law enforcement agency.\" (Def. Mot. at 5). If this \"prosecution against [the defendant] went forward,\" the argument goes, the Minor Victims and their lawyers would \"benefit.\" (Id.)\nThe defendant already has the information relevant to this argument. She has the protocol for the EVCP. The Government has \"offered\" no \"information\" or \"findings\" to the EVCP about the Minor Victims; to the extent the EVCP relied on publicly available information about this case to make its determination, such as the charging instruments in this case, that information is in the public record. And the Government has already disclosed to the defendant the settlement DOJ-OGR-00007396",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page 4 of 8",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "C. Any and All Material Submitted to the EVCP\nThe defendant makes a further request for any and all submissions by the Minor Victims to the EVCP. This request would not generate relevant, admissible evidence for two reasons.\nFirst, the defendant has not identified a theory by which these materials are relevant and admissible. The defendant argues primarily that the materials contain relevant impeachment information because \"[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others.\" (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by Nixon, simply because they aid the defendant's \"understanding.\" And the defendant articulates only one theory by which EVCP materials may be admitted to show bias. According to the defendant, the May 2020 Protocol governing the EVCP states that claims are evaluated depending on whether \"there exists any information and/or pertinent findings offered by the appropriate . . . United States Attorneys' Office or other law enforcement agency.\" (Def. Mot. at 5). If this \"prosecution against [the defendant] went forward,\" the argument goes, the Minor Victims and their lawyers would \"benefit.\" (Id.)\nThe defendant already has the information relevant to this argument. She has the protocol for the EVCP. The Government has \"offered\" no \"information\" or \"findings\" to the EVCP about the Minor Victims; to the extent the EVCP relied on publicly available information about this case to make its determination, such as the charging instruments in this case, that information is in the public record. And the Government has already disclosed to the defendant the settlement",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007396",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Maxwell",
+      "Nixon"
+    ],
+    "organizations": [
+      "Epstein Fund",
+      "United States Attorneys' Office"
+    ],
+    "locations": [],
+    "dates": [
+      "May 2020",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 487",
+      "DOJ-OGR-00007396"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and legible. There are no visible stamps or handwritten annotations."
+}

results/IMAGES003/DOJ-OGR-00007400.json

@@ -0,0 +1,99 @@
+{
+  "document_metadata": {
+    "page_number": "8",
+    "document_number": "487",
+    "date": "11/22/21",
+    "document_type": "Court Document",
+    "has_handwriting": true,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page 8 of 8\nPage 8\nrule as a discovery device.\" United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700.\n\nIII. Conclusion\nFor the foregoing reasons, the Court should quash the defendant's subpoena.7\nRespectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nby: ___________/s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\n(212) 637-2324\ncc: Counsel of Record (by email)\n7 In the event the Court does not quash the subpoena, the Government notes that it is returnable to the Court for in camera review. (Def. Mot. at 1). To the extent the Court releases any records from the EVCP to the defendant, it should only release those records that comply with the Nixon standard. See Skelos, 2018 WL 2254538, at *2 (\"To avoid delay in trial, courts sometimes require production of impeaching material to the court (but not to counsel), with the court reviewing these documents in camera and then disclosing any admissible documents only after the witness testifies.\") For instance, if the Court identifies a prior inconsistent statement in only one document, no other records should be released to the defendant. And, in addition to evaluating whether any statement is relevant to show bias or as a prior inconsistent statement, the Court should consider whether it is precluded under Rule 403, for the reasons described above. See supra pp. 6-7.\nDOJ-OGR-00007400",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page 8 of 8",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 8",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "rule as a discovery device.\" United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "III. Conclusion",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "For the foregoing reasons, the Court should quash the defendant's subpoena.7",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "DAMIAN WILLIAMS\nUnited States Attorney",
+      "position": "body"
+    },
+    {
+      "type": "handwritten",
+      "content": "/s/",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "by: ___________/s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\n(212) 637-2324",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "cc: Counsel of Record (by email)",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "7 In the event the Court does not quash the subpoena, the Government notes that it is returnable to the Court for in camera review. (Def. Mot. at 1). To the extent the Court releases any records from the EVCP to the defendant, it should only release those records that comply with the Nixon standard. See Skelos, 2018 WL 2254538, at *2 (\"To avoid delay in trial, courts sometimes require production of impeaching material to the court (but not to counsel), with the court reviewing these documents in camera and then disclosing any admissible documents only after the witness testifies.\") For instance, if the Court identifies a prior inconsistent statement in only one document, no other records should be released to the defendant. And, in addition to evaluating whether any statement is relevant to show bias or as a prior inconsistent statement, the Court should consider whether it is precluded under Rule 403, for the reasons described above. See supra pp. 6-7.",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007400",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Damian Williams",
+      "Maurene Comey",
+      "Alison Moe",
+      "Lara Pomerantz",
+      "Andrew Rohrbach"
+    ],
+    "organizations": [
+      "United States Attorney"
+    ],
+    "locations": [],
+    "dates": [
+      "11/22/21",
+      "1980"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "487",
+      "630 F.2d 139",
+      "858 F.3d 109",
+      "418 U.S. 700",
+      "2018 WL 2254538"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear structure and formatting. The text is mostly printed, with a single instance of handwritten text (/s/). There are no visible stamps or redactions. The document quality is good, with clear and legible text."
+}

results/IMAGES003/DOJ-OGR-00007402.json

@@ -0,0 +1,70 @@
+{
+  "document_metadata": {
+    "page_number": "2",
+    "document_number": "488",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page 2 of 6\nPage 2\nFor the reasons set forth below, the birth certificates are self-authenticating under Rule 902 of the Federal Rules of Evidence, and no records custodian should be required to testify. The exhibits should be determined to be self-authenticating.\nI. Applicable Law\nRule 902 contains a list of items that are “self-authenticating,” that is “they require no extrinsic evidence of authenticity in order to be admitted.” Fed. R. Evid. 902. Under Rule 902(4), that list includes:\nCertified Copies of Public Records. A copy of an official record — or a copy of a document that was recorded or filed in a public office as authorized by law — if the copy is certified as correct by:\n(A) the custodian or another person authorized to make the certification; or\n(B) a certificate that complies with Rule 902(1), (2), or (3), a federal statute, or a rule prescribed by the Supreme Court.\nRule 902(1), in turn, provides for self-authentication of the following:\nDomestic Public Documents That Are Sealed and Signed. A document that bears:\n(A) a seal purporting to be that of the United States; any state, district, commonwealth, territory, or insular possession of the United States; the former Panama Canal Zone; the Trust Territory of the Pacific Islands; a political subdivision of any of these entities; or a department, agency, or officer of any entity named above; and\n(B) a signature purporting to be an execution or attestation.\nFinally, Federal Rule of Criminal Procedure 27 permits a party to “prove an official record in the same manner as in a civil action.” Federal Rule of Civil Procedure 44(a)(1), in turn, permits proof of a domestic “official record” that is “otherwise admissible and is kept within the United States, any state, district, or commonwealth, or any territory” through\nDOJ-OGR-00007402",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page 2 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "For the reasons set forth below, the birth certificates are self-authenticating under Rule 902 of the Federal Rules of Evidence, and no records custodian should be required to testify. The exhibits should be determined to be self-authenticating.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "I. Applicable Law\nRule 902 contains a list of items that are “self-authenticating,” that is “they require no extrinsic evidence of authenticity in order to be admitted.” Fed. R. Evid. 902. Under Rule 902(4), that list includes:\nCertified Copies of Public Records. A copy of an official record — or a copy of a document that was recorded or filed in a public office as authorized by law — if the copy is certified as correct by:\n(A) the custodian or another person authorized to make the certification; or\n(B) a certificate that complies with Rule 902(1), (2), or (3), a federal statute, or a rule prescribed by the Supreme Court.\nRule 902(1), in turn, provides for self-authentication of the following:\nDomestic Public Documents That Are Sealed and Signed. A document that bears:\n(A) a seal purporting to be that of the United States; any state, district, commonwealth, territory, or insular possession of the United States; the former Panama Canal Zone; the Trust Territory of the Pacific Islands; a political subdivision of any of these entities; or a department, agency, or officer of any entity named above; and\n(B) a signature purporting to be an execution or attestation.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Finally, Federal Rule of Criminal Procedure 27 permits a party to “prove an official record in the same manner as in a civil action.” Federal Rule of Civil Procedure 44(a)(1), in turn, permits proof of a domestic “official record” that is “otherwise admissible and is kept within the United States, any state, district, or commonwealth, or any territory” through",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007402",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "Supreme Court",
+      "United States"
+    ],
+    "locations": [
+      "United States",
+      "Panama Canal Zone",
+      "Pacific Islands"
+    ],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "488",
+      "902",
+      "902(4)",
+      "902(1)",
+      "902(1), (2), or (3)",
+      "27",
+      "44(a)(1)",
+      "DOJ-OGR-00007402"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to the authentication of birth certificates as evidence. The text is well-formatted and printed, with no visible handwriting or stamps. The document is page 2 of 6."
+}

results/IMAGES003/DOJ-OGR-00007403.json

@@ -0,0 +1,67 @@
+{
+  "document_metadata": {
+    "page_number": "3",
+    "document_number": "488",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page 3 of 6\nPage 3\na copy attested by the officer with legal custody of the record—or by the officer's deputy—and accompanied by a certificate that the officer has custody. The certificate must be made under seal:\n. . . (ii) by any public officer with a seal of office and with official duties in the district or political subdivision where the record is kept.\nFed. R Civ. P. 44(a)(1); see Fed. R. Evid. 902 Advisory Committee Notes (\"Rule 44(a) of the Rules of Civil Procedure and Rule 27 of the Rules of Criminal Procedure have provided authentication procedures of this nature for both domestic and foreign public records.\")\nII. Discussion\nThe Minor Victims' birth certificates are certified and sealed by the appropriate officials, and are therefore self-authenticating under Fed. R. Evid. 902(4). See Ball v. A.O. Smith Corp., 451 F.3d 66, 71 (2d Cir. 2006) (\"The original transcript, which includes a certification by the court reporter, is self-authenticating. See Fed. R. Evid. 902(4).\"); United States v. McGee, 439 F. App'x 837, 839 (11th Cir. 2011) (\"We have held that to satisfy the requirements of Rule 902(4), a certification need only identify the legal custodian's position of authority, and that the copy is true and correct.\")\nAt the threshold, domestic birth certificates are \"public records\" within the meaning of Federal Rule of Evidence 902(4). See Fed. R. Evid. 803(9) (providing a hearsay exception for \"Public Records of Vital Statistics,\" including \"[a] record of a birth . . . if reported to a public office in accordance with a legal duty.\")\nPursuant to Rule 902(4)(A), a copy of such a record is self-authenticating if \"certified as correct by: . . . the custodian or another person authorized to make the certification.\" Fed. R. Evid. 902(4)(A). That is the case for each of the birth certificates:\nDOJ-OGR-00007403",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page 3 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 3",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "a copy attested by the officer with legal custody of the record—or by the officer's deputy—and accompanied by a certificate that the officer has custody. The certificate must be made under seal:\n. . . (ii) by any public officer with a seal of office and with official duties in the district or political subdivision where the record is kept.\nFed. R Civ. P. 44(a)(1); see Fed. R. Evid. 902 Advisory Committee Notes (\"Rule 44(a) of the Rules of Civil Procedure and Rule 27 of the Rules of Criminal Procedure have provided authentication procedures of this nature for both domestic and foreign public records.\")",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "II. Discussion",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Minor Victims' birth certificates are certified and sealed by the appropriate officials, and are therefore self-authenticating under Fed. R. Evid. 902(4). See Ball v. A.O. Smith Corp., 451 F.3d 66, 71 (2d Cir. 2006) (\"The original transcript, which includes a certification by the court reporter, is self-authenticating. See Fed. R. Evid. 902(4).\"); United States v. McGee, 439 F. App'x 837, 839 (11th Cir. 2011) (\"We have held that to satisfy the requirements of Rule 902(4), a certification need only identify the legal custodian's position of authority, and that the copy is true and correct.\")",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "At the threshold, domestic birth certificates are \"public records\" within the meaning of Federal Rule of Evidence 902(4). See Fed. R. Evid. 803(9) (providing a hearsay exception for \"Public Records of Vital Statistics,\" including \"[a] record of a birth . . . if reported to a public office in accordance with a legal duty.\")",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Pursuant to Rule 902(4)(A), a copy of such a record is self-authenticating if \"certified as correct by: . . . the custodian or another person authorized to make the certification.\" Fed. R. Evid. 902(4)(A). That is the case for each of the birth certificates:",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007403",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [],
+    "locations": [],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "488",
+      "DOJ-OGR-00007403"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing discussing the authentication of birth certificates under Federal Rules of Evidence."
+}

results/IMAGES003/DOJ-OGR-00007404.json

@@ -0,0 +1,53 @@
+{
+  "document_metadata": {
+    "page_number": "4",
+    "document_number": "488",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page 4 of 6 Page 4 Each of these certifications is a certification by a custodian sufficient to satisfy the Rule. See Ratajack v. Brewster Fire Dept., 178 F. Supp. 3d 118, 128 n.3 (S.D.N.Y. 2016) (concluding that a transcript was self-authenticating based on a court reporter's certification that it contained a \"true record\"). DOJ-OGR-00007404",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page 4 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Each of these certifications is a certification by a custodian sufficient to satisfy the Rule. See Ratajack v. Brewster Fire Dept., 178 F. Supp. 3d 118, 128 n.3 (S.D.N.Y. 2016) (concluding that a transcript was self-authenticating based on a court reporter's certification that it contained a \"true record\").",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007404",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "Brewster Fire Dept.",
+      "DOJ"
+    ],
+    "locations": [
+      "S.D.N.Y."
+    ],
+    "dates": [
+      "11/22/21",
+      "2016"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "488",
+      "DOJ-OGR-00007404"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a header indicating the case number, document number, filing date, and page number. The main content discusses the sufficiency of certifications under a specific rule, referencing a court case. The document is well-formatted and legible."
+}

results/IMAGES003/DOJ-OGR-00007406.json

@@ -0,0 +1,85 @@
+{
+  "document_metadata": {
+    "page_number": "6",
+    "document_number": "488",
+    "date": "11/22/21",
+    "document_type": "Court Document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page 6 of 6\nPage 6\nIII. Conclusion\nFor the foregoing reasons, the Court should determine that the Minor Victims' birth certificates are self-authenticating.\nRespectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nby: /s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\n(212) 637-2324\ncc: Counsel of Record (by email)\nDOJ-OGR-00007406",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page 6 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "III. Conclusion",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "For the foregoing reasons, the Court should determine that the Minor Victims' birth certificates are self-authenticating.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DAMIAN WILLIAMS\nUnited States Attorney",
+      "position": "middle"
+    },
+    {
+      "type": "handwritten",
+      "content": "/s/",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Maurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\n(212) 637-2324",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "cc: Counsel of Record (by email)",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007406",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Damian Williams",
+      "Maurene Comey",
+      "Alison Moe",
+      "Lara Pomerantz",
+      "Andrew Rohrbach"
+    ],
+    "organizations": [
+      "United States Attorney"
+    ],
+    "locations": [],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "488",
+      "DOJ-OGR-00007406"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007407.json

@@ -0,0 +1,87 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "489",
+    "date": "11/22/21",
+    "document_type": "Letter",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 489 Filed 11/22/21 Page 1 of 2 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com November 20, 2021 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the government's letter motion, dated November 11, 2021, requesting that the Court find that the birth certificates for the alleged Minor Victims (GX 11 through GX-16) are self-authenticating under the Federal Rules of Evidence. We have reviewed the government's submission and, in the interests of facilitating an efficient trial, we are prepared to stipulate to the authenticity of the birth certificates for alleged Minor Victim-1 (GX-12), Minor Victim-2 (GX-13), Minor Victim-4 (GX-11), Minor Victim-5 (GX-14), and Minor Victim-6 (GX-15). We will coordinate with the government to produce an appropriately worded stipulation as to the authenticity of these exhibits. However, the government itself concedes that it has not yet proffered a sufficient foundation to authenticate the birth certificate of Witness-3 (GX-16). See 11/11/2021 Gov't Ltr. at 1 n.2. According to GX-16, Witness-3 was born . In order for such a record to be self-authenticating as a foreign public document, the government must meet the requirements of Rule 902(3) of the Federal Rules of Evidence, which it has not yet done. The DOJ-OGR-00007407",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 489 Filed 11/22/21 Page 1 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "November 20, 2021 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan:",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the government's letter motion, dated November 11, 2021, requesting that the Court find that the birth certificates for the alleged Minor Victims (GX 11 through GX-16) are self-authenticating under the Federal Rules of Evidence.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "We have reviewed the government's submission and, in the interests of facilitating an efficient trial, we are prepared to stipulate to the authenticity of the birth certificates for alleged Minor Victim-1 (GX-12), Minor Victim-2 (GX-13), Minor Victim-4 (GX-11), Minor Victim-5 (GX-14), and Minor Victim-6 (GX-15). We will coordinate with the government to produce an appropriately worded stipulation as to the authenticity of these exhibits.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "However, the government itself concedes that it has not yet proffered a sufficient foundation to authenticate the birth certificate of Witness-3 (GX-16). See 11/11/2021 Gov't Ltr. at 1 n.2. According to GX-16, Witness-3 was born . In order for such a record to be self-authenticating as a foreign public document, the government must meet the requirements of Rule 902(3) of the Federal Rules of Evidence, which it has not yet done. The",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007407",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Christian R. Everdell",
+      "Alison J. Nathan",
+      "Ghislaine Maxwell"
+    ],
+    "organizations": [
+      "COHEN & GRESSER LLP",
+      "United States District Court",
+      "United States Courthouse"
+    ],
+    "locations": [
+      "New York",
+      "Southern District of New York",
+      "40 Foley Square"
+    ],
+    "dates": [
+      "November 20, 2021",
+      "November 11, 2021"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 489",
+      "S2 20 Cr. 330 (AJN)",
+      "GX 11",
+      "GX-12",
+      "GX-13",
+      "GX-14",
+      "GX-15",
+      "GX-16",
+      "DOJ-OGR-00007407"
+    ]
+  },
+  "additional_notes": "The document appears to be a formal letter from COHEN & GRESSER LLP to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the authenticity of birth certificates for alleged Minor Victims. There is a redacted section in the document."
+}

results/IMAGES003/DOJ-OGR-00007408.json

@@ -0,0 +1,77 @@
+{
+  "document_metadata": {
+    "page_number": "2",
+    "document_number": "489",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 489 Filed 11/22/21 Page 2 of 2 The Honorable Alison J. Nathan November 20, 2021 Page 2 defense is not prepared to stipulate to the authenticity of a document when the foundation for its authenticity has not yet been established. The defense is willing to reconsider its position if the government can produce the attestations and certifications required to authenticate GX-16 under Rule 902(3). Respectfully submitted, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By Email) DOJ-OGR-00007408",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 489 Filed 11/22/21 Page 2 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan November 20, 2021 Page 2",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "defense is not prepared to stipulate to the authenticity of a document when the foundation for its authenticity has not yet been established. The defense is willing to reconsider its position if the government can produce the attestations and certifications required to authenticate GX-16 under Rule 902(3).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "middle"
+    },
+    {
+      "type": "signature",
+      "content": "/s/ Christian Everdell",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "cc: All Counsel of Record (By Email)",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007408",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Christian Everdell",
+      "Christian R. Everdell"
+    ],
+    "organizations": [
+      "COHEN & GRESSER LLP"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 20, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 489",
+      "GX-16",
+      "DOJ-OGR-00007408"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007409.json

@@ -0,0 +1,107 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "490",
+    "date": "November 15, 2021",
+    "document_type": "Letter",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 490 Filed 11/22/21 Page 1 of 3\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\n\nNovember 15, 2021\n\nVIA EMAIL\n\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\n\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\n\nDear Judge Nathan,\n\nThere are two fundamental flaws with the government's evidentiary proffer regarding proposed Exhibit 52. First, as a matter of fact, Government Exhibit 52 was not something that the cooperating government witness reviewed, used, or saw during her brief employment with Jeffrey Epstein. Records produced in discovery reflect that witness began working for Epstein in\n\nAt that point, the suspect source of Government Exhibit 52, Alfredo Rodriguez, was not employed by Epstein because he had been fired in 2004.\n\nAccording to Mr. Rodriguez, when he left the Epstein home he took an address book, which he claimed was Epstein's book, and had it in his possession until 2009 when he tried to sell it to Brad Edwards for $50,000.1 The book was clearly altered by Mr. Rodriguez. The single\n\n1 Mr. Rodriguez knew the target of his intended sale which makes the likelihood of alteration all the more probable. Mr. Edwards was a lawyer with of the Fort Lauderdale law firm of Rothstein Rosenfelt Adler. The firm was under investigation by the U.S. Attorney for the\n\nDOJ-OGR-00007409",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 490 Filed 11/22/21 Page 1 of 3",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "November 15, 2021",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "VIA EMAIL",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan,",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "There are two fundamental flaws with the government's evidentiary proffer regarding proposed Exhibit 52. First, as a matter of fact, Government Exhibit 52 was not something that the cooperating government witness reviewed, used, or saw during her brief employment with Jeffrey Epstein. Records produced in discovery reflect that witness began working for Epstein in",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "At that point, the suspect source of Government Exhibit 52, Alfredo Rodriguez, was not employed by Epstein because he had been fired in 2004.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "According to Mr. Rodriguez, when he left the Epstein home he took an address book, which he claimed was Epstein's book, and had it in his possession until 2009 when he tried to sell it to Brad Edwards for $50,000.1 The book was clearly altered by Mr. Rodriguez. The single",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1 Mr. Rodriguez knew the target of his intended sale which makes the likelihood of alteration all the more probable. Mr. Edwards was a lawyer with of the Fort Lauderdale law firm of Rothstein Rosenfelt Adler. The firm was under investigation by the U.S. Attorney for the",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007409",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Jeffrey S. Pagliuca",
+      "Alison J. Nathan",
+      "Ghislaine Maxwell",
+      "Jeffrey Epstein",
+      "Alfredo Rodriguez",
+      "Brad Edwards"
+    ],
+    "organizations": [
+      "Haddon, Morgan and Foreman, P.C",
+      "United States District Court",
+      "Southern District of New York",
+      "Rothstein Rosenfelt Adler"
+    ],
+    "locations": [
+      "Denver, Colorado",
+      "New York, NY",
+      "Fort Lauderdale"
+    ],
+    "dates": [
+      "November 15, 2021",
+      "11/22/21",
+      "2004",
+      "2009"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 490",
+      "20 Cr. 330 (AJN)",
+      "DOJ-OGR-00007409"
+    ]
+  },
+  "additional_notes": "The document appears to be a letter from Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the government's evidentiary proffer and highlights two fundamental flaws with proposed Exhibit 52."
+}

results/IMAGES003/DOJ-OGR-00007411.json

@@ -0,0 +1,83 @@
+{
+  "document_metadata": {
+    "page_number": "3",
+    "document_number": "490",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": true,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 490 Filed 11/22/21 Page 3 of 3\nThe Honorable Alison J. Nathan\nNovember 15, 2021\nPage 3\nauthentication. Ms. Maxwell requests that the government be precluded from discussing the book at trial prior to a proper evidentiary foundation being established. In addition, the government should be required to produce the entire book for inspection at trial and counsel for Ms. Maxwell should be afforded an opportunity to conduct voir dire of the exhibit with the proffering witness.\nRespectfully submitted,\nJeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n225 Broadway, Suite 715\nNew York, NY 10007\nPhone: 212-243-1100\nAttorneys for Ghislaine Maxwell\nDOJ-OGR-00007411",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 490 Filed 11/22/21 Page 3 of 3",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nNovember 15, 2021\nPage 3",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "authentication. Ms. Maxwell requests that the government be precluded from discussing the book at trial prior to a proper evidentiary foundation being established. In addition, the government should be required to produce the entire book for inspection at trial and counsel for Ms. Maxwell should be afforded an opportunity to conduct voir dire of the exhibit with the proffering witness.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "middle"
+    },
+    {
+      "type": "handwritten",
+      "content": "signature",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Jeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue\nNew York, NY 10022\nPhone: 212-957-7600\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n225 Broadway, Suite 715\nNew York, NY 10007\nPhone: 212-243-1100",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "Attorneys for Ghislaine Maxwell",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007411",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ghislaine Maxwell",
+      "Jeffrey S. Pagliuca",
+      "Laura A. Menninger",
+      "Christian R. Everdell",
+      "Bobbi C. Sternheim",
+      "Ms. Maxwell"
+    ],
+    "organizations": [
+      "HADDON, MORGAN & FOREMAN P.C.",
+      "COHEN & GRESSER LLP",
+      "Law Offices of Bobbi C. Sternheim"
+    ],
+    "locations": [
+      "Denver, CO",
+      "New York, NY"
+    ],
+    "dates": [
+      "November 15, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 490",
+      "DOJ-OGR-00007411"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is mostly printed, with one handwritten signature. There are no visible stamps or redactions. The document is well-formatted and legible."
+}

results/IMAGES003/DOJ-OGR-00007412.json

@@ -0,0 +1,73 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "491",
+    "date": "11/22/21",
+    "document_type": "Letter",
+    "has_handwriting": false,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page 1 of 6 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 21, 2021 BY E-MAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in reply to the defendant's motion to exclude Government Exhibit 52. (See Dkt. No. 476). The Court ordered the Government to respond in particular to the defendant's argument that \"Employee-1 cannot authenticate Government Exhibit 52 because Mr. Rodriguez, a former employee, purportedly removed the document from the property before Employee-1 began working for Mr. Epstein.\" (Id.) The Second Circuit has \"often commented that the bar for authentication of evidence is not particularly high.\" United States v. Al-Moyad, 545 F.3d 139, 172 (2d Cir. 2008) (alteration and internal quotation marks omitted). The \"proponent of the evidence is not required to rule out all possibilities inconsistent with authenticity, or to prove beyond a reasonable doubt that the evidence is what it purports to be.\" United States v. Dhinsa, 243 F.3d 635, 658 (2d Cir. 2001). All that is required is \"sufficient proof . . . so that a reasonable juror could find in favor of authenticity or 1 DOJ-OGR-00007412",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page 1 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 21, 2021",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "BY E-MAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan: The Government respectfully submits this letter in reply to the defendant's motion to exclude Government Exhibit 52. (See Dkt. No. 476). The Court ordered the Government to respond in particular to the defendant's argument that \"Employee-1 cannot authenticate Government Exhibit 52 because Mr. Rodriguez, a former employee, purportedly removed the document from the property before Employee-1 began working for Mr. Epstein.\" (Id.) The Second Circuit has \"often commented that the bar for authentication of evidence is not particularly high.\" United States v. Al-Moyad, 545 F.3d 139, 172 (2d Cir. 2008) (alteration and internal quotation marks omitted). The \"proponent of the evidence is not required to rule out all possibilities inconsistent with authenticity, or to prove beyond a reasonable doubt that the evidence is what it purports to be.\" United States v. Dhinsa, 243 F.3d 635, 658 (2d Cir. 2001). All that is required is \"sufficient proof . . . so that a reasonable juror could find in favor of authenticity or",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1",
+      "position": "bottom"
+    },
+    {
+      "type": "stamp",
+      "content": "DOJ-OGR-00007412",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ghislaine Maxwell",
+      "Mr. Rodriguez",
+      "Mr. Epstein",
+      "Employee-1"
+    ],
+    "organizations": [
+      "U.S. Department of Justice",
+      "United States Attorney",
+      "United States District Court",
+      "Second Circuit"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 21, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 491",
+      "S2 20 Cr. 330 (AJN)",
+      "Dkt. No. 476",
+      "DOJ-OGR-00007412"
+    ]
+  },
+  "additional_notes": "The document is a letter from the U.S. Department of Justice to the Honorable Alison J. Nathan, regarding the case United States v. Ghislaine Maxwell. The letter discusses the authentication of Government Exhibit 52 and cites relevant case law. The document is stamped with a reference number DOJ-OGR-00007412."
+}

results/IMAGES003/DOJ-OGR-00007416.json

@@ -0,0 +1,52 @@
+{
+  "document_metadata": {
+    "page_number": "5",
+    "document_number": "491",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page 5 of 6\n\n(“During the meeting, the defendant produced a small bound book and several sheets of legal pad paper containing hand-written notes.”). Again, the book is sewn and bound, like the other copies seen by Employee-1, and is not amenable to easy insertion of pages. These “alterations” do not undermine the authenticity of the book in the slightest, but at most, they go to weight and not admissibility. See Tan Yat Chin, 371 F.3d at 38; cf. Gagliardi, 506 F.3d 140, 151 (“Based on the[] testimony [that electronic communications were accurate], a reasonable juror could have found that the exhibits did represent those conversations, notwithstanding that the e-mails and online chats were editable.”).\n\nThe defense is correct that Employee-1 cannot say that she saw the specific address book that is Government Exhibit 52 while she worked for Epstein. But she can recognize Government Exhibit 52 as one of the many copies of the defendant’s address book that she did see, and she can testify to the practice that, close in time to when Government Exhibit 52 left Epstein’s house, the address book was regularly kept in specific places around Epstein’s house. That testimony is enough to satisfy the low bar for authentication, and it is supported by Government Exhibit 606 and by testimony that corroborates private information inside the address book.\n\nDOJ-OGR-00007416",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page 5 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "“During the meeting, the defendant produced a small bound book and several sheets of legal pad paper containing hand-written notes.”). Again, the book is sewn and bound, like the other copies seen by Employee-1, and is not amenable to easy insertion of pages. These “alterations” do not undermine the authenticity of the book in the slightest, but at most, they go to weight and not admissibility. See Tan Yat Chin, 371 F.3d at 38; cf. Gagliardi, 506 F.3d 140, 151 (“Based on the[] testimony [that electronic communications were accurate], a reasonable juror could have found that the exhibits did represent those conversations, notwithstanding that the e-mails and online chats were editable.”).",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "The defense is correct that Employee-1 cannot say that she saw the specific address book that is Government Exhibit 52 while she worked for Epstein. But she can recognize Government Exhibit 52 as one of the many copies of the defendant’s address book that she did see, and she can testify to the practice that, close in time to when Government Exhibit 52 left Epstein’s house, the address book was regularly kept in specific places around Epstein’s house. That testimony is enough to satisfy the low bar for authentication, and it is supported by Government Exhibit 606 and by testimony that corroborates private information inside the address book.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007416",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Employee-1",
+      "Epstein"
+    ],
+    "organizations": [],
+    "locations": [],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 491",
+      "Government Exhibit 52",
+      "Government Exhibit 606",
+      "DOJ-OGR-00007416"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to a criminal case against an individual associated with Epstein. The text discusses the authenticity and admissibility of certain evidence, including an address book."
+}

results/IMAGES003/DOJ-OGR-00007417.json

@@ -0,0 +1,58 @@
+{
+  "document_metadata": {
+    "page_number": "6",
+    "document_number": "491",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page 6 of 6 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by e-mail) DOJ-OGR-00007417",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page 6 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Cc: Defense Counsel (by e-mail)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007417",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Damian Williams",
+      "Maurene Comey",
+      "Alison Moe",
+      "Lara Pomerantz",
+      "Andrew Rohrbach"
+    ],
+    "organizations": [
+      "United States Attorney",
+      "Southern District of New York"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 491",
+      "DOJ-OGR-00007417"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a signature block and a cc section. The text is typed, and there are no visible stamps or handwritten notes."
+}

results/IMAGES003/DOJ-OGR-00007418.json

@@ -0,0 +1,105 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "492",
+    "date": "11/22/21",
+    "document_type": "Letter",
+    "has_handwriting": false,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 1 of 13 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 5, 2021 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in further opposition to the defense motion to exclude evidence of Minor Victim-3 (Dkt. No. 387), and as discussed at the conference on November 1, 2021. As set forth in greater detail below, the testimony of Minor Victim-3 is direct evidence of the offenses charged in the Second Superseding Indictment (the \"Indictment\") and, at a minimum, admissible under multiple bases enumerated in Rule 404(b).1 I. Factual Background The Government expects Minor Victim-3 to testify, in substance and in part, that she met the defendant in or about 1994, when she was approximately 17 years old. 1 The Government moves to file a redacted version of this letter. The proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of Minor Victim-3, who has not been publicly identified, and who is a subject of the Court's order granting the motion to let certain victims and witnesses testify under pseudonyms. DOJ-OGR-00007418",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 1 of 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "U.S. Department of Justice",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "United States Attorney Southern District of New York",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "November 5, 2021",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan:",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The Government respectfully submits this letter in further opposition to the defense motion to exclude evidence of Minor Victim-3 (Dkt. No. 387), and as discussed at the conference on November 1, 2021. As set forth in greater detail below, the testimony of Minor Victim-3 is direct evidence of the offenses charged in the Second Superseding Indictment (the \"Indictment\") and, at a minimum, admissible under multiple bases enumerated in Rule 404(b).1",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "I. Factual Background",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The Government expects Minor Victim-3 to testify, in substance and in part, that she met the defendant in or about 1994, when she was approximately 17 years old.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "1 The Government moves to file a redacted version of this letter. The proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of Minor Victim-3, who has not been publicly identified, and who is a subject of the Court's order granting the motion to let certain victims and witnesses testify under pseudonyms.",
+      "position": "footer"
+    },
+    {
+      "type": "stamp",
+      "content": "DOJ-OGR-00007418",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ghislaine Maxwell",
+      "Minor Victim-3"
+    ],
+    "organizations": [
+      "U.S. Department of Justice",
+      "United States Attorney",
+      "United States District Court"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 5, 2021",
+      "November 1, 2021",
+      "1994",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "20 Cr. 330 (AJN)",
+      "Dkt. No. 387",
+      "DOJ-OGR-00007418"
+    ]
+  },
+  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter includes a stamp with the reference number DOJ-OGR-00007418."
+}

results/IMAGES003/DOJ-OGR-00007419.json

@@ -0,0 +1,44 @@
+{
+  "document_metadata": {
+    "page_number": "2",
+    "document_number": "492",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 2 of 13 Page 2 DOJ-OGR-00007419",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 2 of 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 2",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007419",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "DOJ"
+    ],
+    "locations": [],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "492",
+      "DOJ-OGR-00007419"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with redactions throughout the body. The text is mostly obscured by black bars, indicating sensitive or confidential information has been redacted."
+}

results/IMAGES003/DOJ-OGR-00007420.json

@@ -0,0 +1,63 @@
+{
+  "document_metadata": {
+    "page_number": "3",
+    "document_number": "492",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 3 of 13\nPage 3\n\n\n\n\n\n\n\n\n\n\n\nII. Applicable Law\nRelevant evidence is \"not confined to that which directly establishes an element of the crime.\" United States v. Gonzalez, 110 F.3d 941, 942 (2d Cir. 1997). As the Second Circuit has explained, \"[t]o be relevant, evidence need only tend to prove the government's case, and evidence that adds context and dimension to the government's proof of the charges can have that tendency.\" Id. The Second Circuit has also repeatedly held that actions and statements are admissible as direct evidence of the crimes charged, and are \"not considered other crimes evidence under\" Federal Rule of Evidence 404(b), if (a) they \"arose out of the same transaction or series of transactions as the charged offense,\" (b) they are \"inextricably intertwined with the evidence regarding the charged offense,\" or (c) they are \"necessary to complete the story of the crime on trial.\" United States v. Carboni, 204 F.3d 39, 44 (2d Cir. 2000); see also United States v. Quinones, 511 F.3d 289, 309 (2d Cir. 2007); United States v. Baez, 349 F.3d 90, 93-94 (2d Cir. 2003). In those\nDOJ-OGR-00007420",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 3 of 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 3",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "II. Applicable Law",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Relevant evidence is \"not confined to that which directly establishes an element of the crime.\" United States v. Gonzalez, 110 F.3d 941, 942 (2d Cir. 1997). As the Second Circuit has explained, \"[t]o be relevant, evidence need only tend to prove the government's case, and evidence that adds context and dimension to the government's proof of the charges can have that tendency.\" Id. The Second Circuit has also repeatedly held that actions and statements are admissible as direct evidence of the crimes charged, and are \"not considered other crimes evidence under\" Federal Rule of Evidence 404(b), if (a) they \"arose out of the same transaction or series of transactions as the charged offense,\" (b) they are \"inextricably intertwined with the evidence regarding the charged offense,\" or (c) they are \"necessary to complete the story of the crime on trial.\" United States v. Carboni, 204 F.3d 39, 44 (2d Cir. 2000); see also United States v. Quinones, 511 F.3d 289, 309 (2d Cir. 2007); United States v. Baez, 349 F.3d 90, 93-94 (2d Cir. 2003). In those",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007420",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [],
+    "organizations": [
+      "Second Circuit",
+      "United States"
+    ],
+    "locations": [],
+    "dates": [
+      "11/22/21",
+      "1997",
+      "2000",
+      "2007",
+      "2003"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 492",
+      "110 F.3d 941",
+      "204 F.3d 39",
+      "511 F.3d 289",
+      "349 F.3d 90",
+      "DOJ-OGR-00007420"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly printed, with no visible handwriting or stamps. The document is from a legal case, and the content discusses applicable law regarding relevant evidence in a criminal trial."
+}

results/IMAGES003/DOJ-OGR-00007422.json

@@ -0,0 +1,56 @@
+{
+  "document_metadata": {
+    "page_number": "5",
+    "document_number": "492",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 5 of 13\nPage 5\ncharged in the Indictment. But even if it is not, it is certainly admissible under Rule 404(b).\nA. Direct Evidence\nAs the Government argued in its motion, evidence relating to Minor Victim-3 is direct evidence of the Mann Act conspiracies. The defendant's conduct regarding Minor Victim-3 overlaps in time and place with the other Minor Victims charged in the Mann Act conspiracies:\nCounts One and Three charge conduct from 1994 to 2004 in New York and Palm Beach, and Minor Victim-3 began giving Epstein sexualized massages in 1994, traveling to meet Epstein and the defendant in both New York and Palm Beach. The Government expects the defendant's relationship with Epstein to be a \"critical factual dispute\"—specifically, whether that relationship included conspiring with him and aiding or abetting Epstein's sex crimes. United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012). Minor Victim-3's testimony will help establish that it did.\nEvidence relating to Minor Victim-3 also \"fills in a narrative\" about \"why [the defendant] took actions to\" arrange sexualized massages. United States v. Rodriguez, 727 F. App'x 24, 26 (2d Cir. 2018) (summary order).\nFinally, evidence related to Minor Victim-3 is direct evidence as corroboration for the other three Minor Victims. Those Minor Victims will describe a conspiracy that operated to recruit girls for the purposes of massage, groom them, and transform the massages into sexual encounters. The conspirators then traveled with the girls or invited girls to travel, and asked the girls to find others for Epstein.\nDOJ-OGR-00007422",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 5 of 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 5",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "charged in the Indictment. But even if it is not, it is certainly admissible under Rule 404(b).\nA. Direct Evidence\nAs the Government argued in its motion, evidence relating to Minor Victim-3 is direct evidence of the Mann Act conspiracies. The defendant's conduct regarding Minor Victim-3 overlaps in time and place with the other Minor Victims charged in the Mann Act conspiracies:\nCounts One and Three charge conduct from 1994 to 2004 in New York and Palm Beach, and Minor Victim-3 began giving Epstein sexualized massages in 1994, traveling to meet Epstein and the defendant in both New York and Palm Beach. The Government expects the defendant's relationship with Epstein to be a \"critical factual dispute\"—specifically, whether that relationship included conspiring with him and aiding or abetting Epstein's sex crimes. United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012). Minor Victim-3's testimony will help establish that it did.\nEvidence relating to Minor Victim-3 also \"fills in a narrative\" about \"why [the defendant] took actions to\" arrange sexualized massages. United States v. Rodriguez, 727 F. App'x 24, 26 (2d Cir. 2018) (summary order).\nFinally, evidence related to Minor Victim-3 is direct evidence as corroboration for the other three Minor Victims. Those Minor Victims will describe a conspiracy that operated to recruit girls for the purposes of massage, groom them, and transform the massages into sexual encounters. The conspirators then traveled with the girls or invited girls to travel, and asked the girls to find others for Epstein.",
+      "position": "main"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007422",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Epstein"
+    ],
+    "organizations": [
+      "Government"
+    ],
+    "locations": [
+      "New York",
+      "Palm Beach"
+    ],
+    "dates": [
+      "11/22/21",
+      "1994",
+      "2004"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 492",
+      "DOJ-OGR-00007422"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text discusses the admissibility of evidence related to Minor Victim-3 and its relevance to the Mann Act conspiracies. There are no visible redactions or damage to the document."
+}

results/IMAGES003/DOJ-OGR-00007424.json

@@ -0,0 +1,69 @@
+{
+  "document_metadata": {
+    "page_number": "7",
+    "document_number": "492",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 7 of 13 Page 7 to engage in commercial sex acts, an element of the offense. The latter is evidence that the defendant and Epstein engaged in sex trafficking of minors, which requires that the minor victim be under eighteen rather than seventeen. Minor Victim-3's testimony will show that she had sexual encounters with Epstein, and in combination with the testimony of other Minor Victims, the evidence will show that Epstein continually sought out girls under the age of 18 for sex from 1994 through the time period of the sex trafficking conspiracy.2 B. Rule 404(b) In any event, evidence relating to Minor Victim-3 is relevant for multiple purposes that are permissible under Rule 404(b). First, it is relevant to the defendant's knowledge that the massages were sexualized, an issue that is expected to be central at this trial. The Government anticipates that Minor Victim-3 will describe [redacted sections] A jury could conclude from each of these facts that 2 Evidence related to Minor Victim-3 is similarly relevant to the Mann Act counts. The Mann Act counts require that the victims be under seventeen, rather than eighteen. But evidence that Epstein had a sexual preference for women much younger than him, including seventeen-year-olds, is probative of whether he had a sexual preference for sixteen-year-olds. DOJ-OGR-00007424",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 7 of 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 7",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "to engage in commercial sex acts, an element of the offense. The latter is evidence that the defendant and Epstein engaged in sex trafficking of minors, which requires that the minor victim be under eighteen rather than seventeen. Minor Victim-3's testimony will show that she had sexual encounters with Epstein, and in combination with the testimony of other Minor Victims, the evidence will show that Epstein continually sought out girls under the age of 18 for sex from 1994 through the time period of the sex trafficking conspiracy.2",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "B. Rule 404(b)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "In any event, evidence relating to Minor Victim-3 is relevant for multiple purposes that are permissible under Rule 404(b). First, it is relevant to the defendant's knowledge that the massages were sexualized, an issue that is expected to be central at this trial. The Government anticipates that Minor Victim-3 will describe [redacted sections] A jury could conclude from each of these facts that",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "2 Evidence related to Minor Victim-3 is similarly relevant to the Mann Act counts. The Mann Act counts require that the victims be under seventeen, rather than eighteen. But evidence that Epstein had a sexual preference for women much younger than him, including seventeen-year-olds, is probative of whether he had a sexual preference for sixteen-year-olds.",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007424",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Epstein",
+      "Minor Victim-3",
+      "defendant"
+    ],
+    "organizations": [
+      "Government"
+    ],
+    "locations": [],
+    "dates": [
+      "11/22/21",
+      "1994"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 492",
+      "DOJ-OGR-00007424"
+    ]
+  },
+  "additional_notes": "The document contains redactions in the main body."
+}

results/IMAGES003/DOJ-OGR-00007425.json

@@ -0,0 +1,70 @@
+{
+  "document_metadata": {
+    "page_number": "8",
+    "document_number": "492",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 8 of 13\nPage 8\nthe defendant knew that, when she arranged for a young girl—such as Minor Victim-1 or Minor Victim-4—to give Epstein a massage, that massage involved sexual contact.\nSecond, the evidence is relevant to the defendant’s motive. The Government expects the defense to argue that the defendant had no reason to assist Epstein in obtaining sexualized massages, especially from young girls. Minor Victim-3 will testify that\n\n\n\nThird, evidence regarding Minor Victim-3 is probative of her intent. “‘Where intent to commit the crime charged is clearly at issue’—i.e., where it is an element of the crime—‘evidence of prior similar acts may be introduced to prove that intent.’” United States v. Graham, No. 14 Cr. 500 (NSR), 2015 WL 6161292, at *3 (S.D.N.Y. Oct. 20, 2015) (quoting United States v. Caputo, 808 F.2d 963, 968 (2d Cir. 1987)). The defendant is likely to argue that any steps taken to arrange massages were purely innocent conduct. See id. (“Prior act evidence is admissible to demonstrate intent ‘where a defendant claims that his conduct has an innocent explanation.’” (quoting Zackson, 12 F.3d at 1182 (alterations omitted))). Evidence of the defendant’s knowledge that massages were sexualized and the defendant’s motives described above is probative of her intent to entice and transport minors for the purpose of sexual contact. Minor Victim-3’s sexualized massages began around the time the conspiracy started, yet the massages continued—with the defendant’s active involvement, as to Minor Victim-3 and other Minor Victims—for years. That is highly probative evidence of her intent as to each of the conspiracies charged in the Indictment. And Minor Victim-3’s testimony contains additional evidence of the defendant’s intent. For instance,",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 8 of 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 8",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "the defendant knew that, when she arranged for a young girl—such as Minor Victim-1 or Minor Victim-4—to give Epstein a massage, that massage involved sexual contact.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Second, the evidence is relevant to the defendant’s motive. The Government expects the defense to argue that the defendant had no reason to assist Epstein in obtaining sexualized massages, especially from young girls. Minor Victim-3 will testify that",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Third, evidence regarding Minor Victim-3 is probative of her intent. “‘Where intent to commit the crime charged is clearly at issue’—i.e., where it is an element of the crime—‘evidence of prior similar acts may be introduced to prove that intent.’” United States v. Graham, No. 14 Cr. 500 (NSR), 2015 WL 6161292, at *3 (S.D.N.Y. Oct. 20, 2015) (quoting United States v. Caputo, 808 F.2d 963, 968 (2d Cir. 1987)). The defendant is likely to argue that any steps taken to arrange massages were purely innocent conduct. See id. (“Prior act evidence is admissible to demonstrate intent ‘where a defendant claims that his conduct has an innocent explanation.’” (quoting Zackson, 12 F.3d at 1182 (alterations omitted))). Evidence of the defendant’s knowledge that massages were sexualized and the defendant’s motives described above is probative of her intent to entice and transport minors for the purpose of sexual contact. Minor Victim-3’s sexualized massages began around the time the conspiracy started, yet the massages continued—with the defendant’s active involvement, as to Minor Victim-3 and other Minor Victims—for years. That is highly probative evidence of her intent as to each of the conspiracies charged in the Indictment. And Minor Victim-3’s testimony contains additional evidence of the defendant’s intent. For instance,",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007425",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Epstein",
+      "Minor Victim-1",
+      "Minor Victim-3",
+      "Minor Victim-4"
+    ],
+    "organizations": [
+      "Government"
+    ],
+    "locations": [
+      "S.D.N.Y."
+    ],
+    "dates": [
+      "11/22/21",
+      "Oct. 20, 2015"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 492",
+      "14 Cr. 500 (NSR)",
+      "2015 WL 6161292",
+      "808 F.2d 963",
+      "12 F.3d at 1182"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein and the defendant. The text discusses the relevance of evidence regarding Minor Victim-3's testimony and its probative value in establishing the defendant's intent. The document is well-formatted and free of significant damage or redactions."
+}

results/IMAGES003/DOJ-OGR-00007426.json

@@ -0,0 +1,73 @@
+{
+  "document_metadata": {
+    "page_number": "9",
+    "document_number": "492",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 9 of 13\nPage 9\nthe Government anticipates that Minor Victim-3 will testify that\nFourth, evidence relating to Minor Victim-3 is evidence of the conspiracy's plan or modus operandi. \"[T]o establish a recurring modus operandi . . . it is enough that the characteristics relied upon are sufficiently idiosyncratic to permit a fair inference of a pattern's existence.\" United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). The pattern here is highly idiosyncratic. The defendant identified Minor Victim-3, befriended her, and invited her over.\nAll\nthis happened during the conspiracy, and at least one of the other Minor Victims will testify to each step in this pattern. \"[T]aken together, they establish the existence of a pattern.\" United States v. Carlton, 534 F.3d 97, 102 (2d Cir. 2008).\nThe defense argues that none of this is probative under Rule 404(b) because Minor Victim-3 was above the age of consent, so evidence relating to Minor Victim-3 is not probative of the defendant's \"intent of doing something illegal,\" such as a sex act with a minor. (11/01/21 Tr. 82:8-16). That, however, is just a way of repeating that all the elements of the offense are not satisfied as to Minor Victim-3. But evidence relating to Minor Victim-3 is probative of central questions about the defendant's knowledge, motive, intent, and role in the conspiracy. For instance, the Government expects that the defense may challenge (1) whether the defendant played a role in recruiting girls to give Epstein massages; (2) whether those girls were below or near the age of consent; (3) whether the defendant instructed those girls to give Epstein a massage, including by\nDOJ-OGR-00007426",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 9 of 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 9",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "the Government anticipates that Minor Victim-3 will testify that",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Fourth, evidence relating to Minor Victim-3 is evidence of the conspiracy's plan or modus operandi. \"[T]o establish a recurring modus operandi . . . it is enough that the characteristics relied upon are sufficiently idiosyncratic to permit a fair inference of a pattern's existence.\" United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). The pattern here is highly idiosyncratic. The defendant identified Minor Victim-3, befriended her, and invited her over.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "All",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "this happened during the conspiracy, and at least one of the other Minor Victims will testify to each step in this pattern. \"[T]aken together, they establish the existence of a pattern.\" United States v. Carlton, 534 F.3d 97, 102 (2d Cir. 2008).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The defense argues that none of this is probative under Rule 404(b) because Minor Victim-3 was above the age of consent, so evidence relating to Minor Victim-3 is not probative of the defendant's \"intent of doing something illegal,\" such as a sex act with a minor. (11/01/21 Tr. 82:8-16). That, however, is just a way of repeating that all the elements of the offense are not satisfied as to Minor Victim-3. But evidence relating to Minor Victim-3 is probative of central questions about the defendant's knowledge, motive, intent, and role in the conspiracy. For instance, the Government expects that the defense may challenge (1) whether the defendant played a role in recruiting girls to give Epstein massages; (2) whether those girls were below or near the age of consent; (3) whether the defendant instructed those girls to give Epstein a massage, including by",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007426",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Minor Victim-3",
+      "Epstein"
+    ],
+    "organizations": [
+      "Government"
+    ],
+    "locations": [],
+    "dates": [
+      "11/22/21",
+      "11/01/21"
+    ],
+    "reference_numbers": [
+      "Case 1:20-cr-00330-PAE",
+      "Document 492",
+      "DOJ-OGR-00007426"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text is mostly printed, with some redacted sections. There are no visible stamps or handwritten notes."
+}

results/IMAGES003/DOJ-OGR-00007430.json

@@ -0,0 +1,68 @@
+{
+  "document_metadata": {
+    "page_number": "13",
+    "document_number": "492",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 13 of 13\nPage 13\nthe Court make sure the jury understands its point: the instruction should say that Minor Victim-3 was above the age of consent at all relevant times, but it should also say expressly that the jury can consider her evidence as direct evidence or for all of the permissible purposes under Rule 404(b).\nThat result, and the admission of her testimony, is entirely proper.\nRespectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nBy: s/\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nCc: Defense Counsel (By E-mail)\nDOJ-OGR-00007430",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 13 of 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 13",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "the Court make sure the jury understands its point: the instruction should say that Minor Victim-3 was above the age of consent at all relevant times, but it should also say expressly that the jury can consider her evidence as direct evidence or for all of the permissible purposes under Rule 404(b).\nThat result, and the admission of her testimony, is entirely proper.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nBy: s/\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Cc: Defense Counsel (By E-mail)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007430",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "DAMIAN WILLIAMS",
+      "Alison Moe",
+      "Lara Pomerantz",
+      "Andrew Rohrbach",
+      "Minor Victim-3"
+    ],
+    "organizations": [
+      "United States Attorney",
+      "Southern District of New York"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 492",
+      "DOJ-OGR-00007430"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007431.json

@@ -0,0 +1,88 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "493",
+    "date": "11/22/21",
+    "document_type": "Letter",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page 1 of 6\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nNovember 7, 2021\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's order directing the Government to state its position as to whether Minor Victim-3 \"could be deemed a victim of any of the crimes charged in the indictment for any legal purposes, including for purposes of restitution under 18 U.S.C. § 3663(a)(2).\" The answer is yes. Minor Victim-3 suffered unwanted and traumatic sexual contact with Jeffrey Epstein when she was 17 years old. In addition to making her a victim in the ordinary sense of that word, it makes her a victim of the charged Mann Act conspiracies for at least the following provisions of federal law: the Crime Victim's Rights Act (\"CVRA\"), 18 U.S.C. § 3771; the Victim and Witness Protection Act (\"VWPA\"), 18 U.S.C. § 3663; and Federal Rule of Evidence 412.1\nBoth the CVRA and VWPA contain statutory definitions of the term \"victim.\" The CVRA defines \"victim\" as \"a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia.\" 18 U.S.C. § 3771(e)(2)(A). The VWPA similarly defines \"victim\" to mean \"a person directly and proximately harmed by the commission of the offense.\"1\nGiven the expedited briefing deadline, the Government has not addressed every provision of federal law that references victims, but would be happy to address any additional provisions the Court deems relevant.\nDOJ-OGR-00007431",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page 1 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "November 7, 2021",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan:",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The Government respectfully submits this letter in response to the Court's order directing the Government to state its position as to whether Minor Victim-3 \"could be deemed a victim of any of the crimes charged in the indictment for any legal purposes, including for purposes of restitution under 18 U.S.C. § 3663(a)(2).\" The answer is yes. Minor Victim-3 suffered unwanted and traumatic sexual contact with Jeffrey Epstein when she was 17 years old. In addition to making her a victim in the ordinary sense of that word, it makes her a victim of the charged Mann Act conspiracies for at least the following provisions of federal law: the Crime Victim's Rights Act (\"CVRA\"), 18 U.S.C. § 3771; the Victim and Witness Protection Act (\"VWPA\"), 18 U.S.C. § 3663; and Federal Rule of Evidence 412.1",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Both the CVRA and VWPA contain statutory definitions of the term \"victim.\" The CVRA defines \"victim\" as \"a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia.\" 18 U.S.C. § 3771(e)(2)(A). The VWPA similarly defines \"victim\" to mean \"a person directly and proximately harmed by the commission of the offense.\"1",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Given the expedited briefing deadline, the Government has not addressed every provision of federal law that references victims, but would be happy to address any additional provisions the Court deems relevant.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007431",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ghislaine Maxwell",
+      "Jeffrey Epstein"
+    ],
+    "organizations": [
+      "U.S. Department of Justice",
+      "United States Attorney",
+      "United States District Court"
+    ],
+    "locations": [
+      "New York",
+      "District of Columbia"
+    ],
+    "dates": [
+      "November 7, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "20 Cr. 330 (AJN)",
+      "DOJ-OGR-00007431"
+    ]
+  },
+  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The document is typed and contains legal terminology and references to specific laws and regulations."
+}

results/IMAGES003/DOJ-OGR-00007435.json

@@ -0,0 +1,55 @@
+{
+  "document_metadata": {
+    "page_number": "5",
+    "document_number": "493",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page 5 of 6\nPage 5\nharmed by conduct in furtherance of the conspiracy—and she was—then she is a “victim” under the relevant statutes.\n\nFinally, Minor Victim-3 is also a “victim” for purposes of Federal Rule of Evidence 412, because she is clearly someone who “can reasonably be characterized as a ‘victim of alleged sexual misconduct.’” Fed. R. Evid. 412, Advisory Committee Notes (1994). Given Rule 412’s broad application in not just criminal cases but also civil cases such as claims of sexual harassment, see Wolak v. Spucci, 217 F.3d 157, 160 (2d Cir. 2000), it cannot be read to define victims as only those individuals whose victimization would alone satisfy all of the elements of a charged crime. As set forth above, Epstein’s conduct with respect to Minor Victim-3 is plainly “alleged sexual misconduct,” and therefore she is a victim as defined in Rule 412.\n\nFor these reasons, Minor Victim-3 is a “victim” under the provisions of federal law discussed above. Moreover, the Government respectfully submits that even if its reading of these provisions is incorrect, that does not affect the admissibility of Minor Victim-3’s testimony as direct evidence: evidence that does not itself establish every element of the charged crime may nevertheless be admissible as direct evidence. See, e.g., United States v. Gonzalez, 110 F.3d 941, 942 (2d Cir. 1997); United States v. Carboni, 204 F.3d 39, 44 (2d Cir. 2000). And Minor Victim-3’s status as a “victim” under the foregoing provisions of law certainly does not affect the admissibility of her testimony under Rule 404(b), which permits the admission of other act testimony that almost by definition does not satisfy the elements of the charged crime. The testimony should be admitted.\n\nDOJ-OGR-00007435",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page 5 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 5",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "harmed by conduct in furtherance of the conspiracy—and she was—then she is a “victim” under the relevant statutes.\n\nFinally, Minor Victim-3 is also a “victim” for purposes of Federal Rule of Evidence 412, because she is clearly someone who “can reasonably be characterized as a ‘victim of alleged sexual misconduct.’” Fed. R. Evid. 412, Advisory Committee Notes (1994). Given Rule 412’s broad application in not just criminal cases but also civil cases such as claims of sexual harassment, see Wolak v. Spucci, 217 F.3d 157, 160 (2d Cir. 2000), it cannot be read to define victims as only those individuals whose victimization would alone satisfy all of the elements of a charged crime. As set forth above, Epstein’s conduct with respect to Minor Victim-3 is plainly “alleged sexual misconduct,” and therefore she is a victim as defined in Rule 412.\n\nFor these reasons, Minor Victim-3 is a “victim” under the provisions of federal law discussed above. Moreover, the Government respectfully submits that even if its reading of these provisions is incorrect, that does not affect the admissibility of Minor Victim-3’s testimony as direct evidence: evidence that does not itself establish every element of the charged crime may nevertheless be admissible as direct evidence. See, e.g., United States v. Gonzalez, 110 F.3d 941, 942 (2d Cir. 1997); United States v. Carboni, 204 F.3d 39, 44 (2d Cir. 2000). And Minor Victim-3’s status as a “victim” under the foregoing provisions of law certainly does not affect the admissibility of her testimony under Rule 404(b), which permits the admission of other act testimony that almost by definition does not satisfy the elements of the charged crime. The testimony should be admitted.",
+      "position": "main content"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007435",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Minor Victim-3",
+      "Epstein"
+    ],
+    "organizations": [
+      "Government"
+    ],
+    "locations": [],
+    "dates": [
+      "11/22/21",
+      "1994",
+      "2000",
+      "1997"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 493",
+      "DOJ-OGR-00007435"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text discusses the admissibility of testimony from Minor Victim-3 under various federal rules of evidence. The document is well-formatted and free of significant damage or redactions."
+}

results/IMAGES003/DOJ-OGR-00007436.json

@@ -0,0 +1,72 @@
+{
+  "document_metadata": {
+    "page_number": "6",
+    "document_number": "493",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page 6 of 6\nPage 6\nRespectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nBy: s/\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nCc: Defense Counsel\nDOJ-OGR-00007436",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page 6 of 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Page 6",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DAMIAN WILLIAMS\nUnited States Attorney",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "By: s/\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Cc: Defense Counsel",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007436",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Damian Williams",
+      "Alison Moe",
+      "Lara Pomerantz",
+      "Andrew Rohrbach"
+    ],
+    "organizations": [
+      "United States Attorney",
+      "Southern District of New York"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "493",
+      "DOJ-OGR-00007436"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007437.json

@@ -0,0 +1,96 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "494",
+    "date": "11/22/21",
+    "document_type": "Letter",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 1 of 12 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com November 11, 2021 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to (i) the government's November 5, 2021 letter in further opposition to Ms. Maxwell's Motion in Limine to Exclude Evidence Related to Accuser-3 (Dkt. 387), and (ii) the government's November 7, 2021 letter in response to the Court's order, dated November 6, 2021, directing the government \"to state its position as to whether this anticipated witness could be deemed a victim of any of the crimes charged in the indictment for any legal purpose.\" (Dkt. 417). For the reasons set forth below and in our prior motion, the evidence related to Accuser-3 is not direct evidence of any of the conspiracies charged in the S2 Indictment and is improper propensity evidence that should be excluded under Rule 404(b) and Rule 403 of the Federal Rules of Evidence. I. Accuser-3's Evidence Is Not Direct Evidence of Any Conspiracy Charged in the S2 Indictment The Court asked the government to do two things at the November 1, 2021 pretrial conference concerning the admissibility of Accuser-3's evidence: (i) provide additional briefing on why Accuser-3's evidence could potentially be admitted as direct evidence of the sex trafficking conspiracy charged in Count Five, and (ii) outline in further detail Accuser-3's 2049808.1 DOJ-OGR-00007437",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 1 of 12",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "November 11, 2021",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to (i) the government's November 5, 2021 letter in further opposition to Ms. Maxwell's Motion in Limine to Exclude Evidence Related to Accuser-3 (Dkt. 387), and (ii) the government's November 7, 2021 letter in response to the Court's order, dated November 6, 2021, directing the government \"to state its position as to whether this anticipated witness could be deemed a victim of any of the crimes charged in the indictment for any legal purpose.\" (Dkt. 417). For the reasons set forth below and in our prior motion, the evidence related to Accuser-3 is not direct evidence of any of the conspiracies charged in the S2 Indictment and is improper propensity evidence that should be excluded under Rule 404(b) and Rule 403 of the Federal Rules of Evidence.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "I. Accuser-3's Evidence Is Not Direct Evidence of Any Conspiracy Charged in the S2 Indictment",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Court asked the government to do two things at the November 1, 2021 pretrial conference concerning the admissibility of Accuser-3's evidence: (i) provide additional briefing on why Accuser-3's evidence could potentially be admitted as direct evidence of the sex trafficking conspiracy charged in Count Five, and (ii) outline in further detail Accuser-3's",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "2049808.1 DOJ-OGR-00007437",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Christian R. Everdell",
+      "Alison J. Nathan",
+      "Ghislaine Maxwell"
+    ],
+    "organizations": [
+      "COHEN & GRESSER LLP",
+      "United States District Court",
+      "United States Courthouse"
+    ],
+    "locations": [
+      "New York",
+      "Southern District of New York"
+    ],
+    "dates": [
+      "November 11, 2021",
+      "November 5, 2021",
+      "November 7, 2021",
+      "November 6, 2021",
+      "November 1, 2021"
+    ],
+    "reference_numbers": [
+      "Case 1:20-cr-00330-PAE",
+      "Document 494",
+      "S2 20 Cr. 330 (AJN)",
+      "Dkt. 387",
+      "Dkt. 417",
+      "2049808.1",
+      "DOJ-OGR-00007437"
+    ]
+  },
+  "additional_notes": "The document appears to be a formal legal letter, with no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007439.json

@@ -0,0 +1,71 @@
+{
+  "document_metadata": {
+    "page_number": "3",
+    "document_number": "494",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 3 of 12\n\nThe Honorable Alison J. Nathan\nNovember 11, 2021\nPage 3\n\nThe government devotes only a single paragraph to explaining why Accuser-3's evidence is admissible as direct evidence of the sex trafficking conspiracy charged in Count Five. See November 5 Ltr. at 6-7. The few reasons the government does give are meritless. The government starts by asserting that Accuser-3's evidence is admissible to prove the sex trafficking conspiracy for the same reasons that it is admissible to prove the Mann Act conspiracies - reasons which the Court has already rejected. See id. at 6. The government then makes the puzzling assertion that Accuser-3's evidence is admissible because it \"demonstrates the reasons for a co-conspirator's participation in the conspiracy.\" Id. Specifically, the government asserts that the evidence shows that (1) \"minors who gave sexualized massages to Epstein were compensated,\" which the government contends is proof that Ms. Maxwell and Epstein \"recruited and enticed girls to engage in commercial sex acts\"; and (2) \"Epstein was sexually attracted to girls of a certain age, typically under the age of eighteen,\" which the government contends is proof that Ms. Maxwell and Epstein engaged in sex trafficking of minors under the age of eighteen. Id. at 6-7.\n\nThese arguments are misguided and unpersuasive. First, neither of the two specific bases for admission speaks to \"the reasons for\" Ms. Maxwell's alleged participation in the sex trafficking conspiracy, as the government claims. Second, the two specific bases for admission are legally and factually flawed.\n\nAs to the issue of compensation,",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 3 of 12",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nNovember 11, 2021\nPage 3",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "The government devotes only a single paragraph to explaining why Accuser-3's evidence is admissible as direct evidence of the sex trafficking conspiracy charged in Count Five. See November 5 Ltr. at 6-7. The few reasons the government does give are meritless. The government starts by asserting that Accuser-3's evidence is admissible to prove the sex trafficking conspiracy for the same reasons that it is admissible to prove the Mann Act conspiracies - reasons which the Court has already rejected. See id. at 6. The government then makes the puzzling assertion that Accuser-3's evidence is admissible because it \"demonstrates the reasons for a co-conspirator's participation in the conspiracy.\" Id. Specifically, the government asserts that the evidence shows that (1) \"minors who gave sexualized massages to Epstein were compensated,\" which the government contends is proof that Ms. Maxwell and Epstein \"recruited and enticed girls to engage in commercial sex acts\"; and (2) \"Epstein was sexually attracted to girls of a certain age, typically under the age of eighteen,\" which the government contends is proof that Ms. Maxwell and Epstein engaged in sex trafficking of minors under the age of eighteen. Id. at 6-7.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "These arguments are misguided and unpersuasive. First, neither of the two specific bases for admission speaks to \"the reasons for\" Ms. Maxwell's alleged participation in the sex trafficking conspiracy, as the government claims. Second, the two specific bases for admission are legally and factually flawed.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "As to the issue of compensation,",
+      "position": "middle"
+    },
+    {
+      "type": "other",
+      "content": "redacted text",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "2049808.1\nDOJ-OGR-00007439",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Ms. Maxwell",
+      "Epstein",
+      "Accuser-3"
+    ],
+    "organizations": [],
+    "locations": [],
+    "dates": [
+      "November 11, 2021",
+      "11/22/21",
+      "November 5"
+    ],
+    "reference_numbers": [
+      "Case 1:20-cr-00330-PAE",
+      "Document 494",
+      "Count Five",
+      "2049808.1",
+      "DOJ-OGR-00007439"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to the case against Ms. Maxwell. The text is mostly printed, with some redacted sections at the bottom of the page. The document is page 3 of a 12-page filing."
+}

results/IMAGES003/DOJ-OGR-00007440.json

@@ -0,0 +1,70 @@
+{
+  "document_metadata": {
+    "page_number": "4",
+    "document_number": "494",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 4 of 12\nThe Honorable Alison J. Nathan\nNovember 11, 2021\nPage 4\nHence, even if we assume for the sake of argument that everything Accuser-3 told the government is true (which we do not concede), her testimony would not in any way establish that \"minors who gave sexualized massages to Epstein were compensated.\" Accuser-3, quite simply, was not under the age of eighteen and was therefore not a minor (under any relevant federal or state statute) when she allegedly . Second, as a factual matter, the government is talking out of both sides of its mouth. The government cannot offer Accuser-3's testimony as proof of a sex trafficking conspiracy when Accuser-3's own statements therefore eliminate any basis for the admission of her testimony as direct evidence of Count Five.\nAs to the issue of Epstein's sexual attraction to young women, the government is once again impermissibly attempting to use an example of entirely legal conduct as proof of a conspiracy to engage in illegal conduct. Accuser-3's evidence does not show that Epstein was attracted to underage girls. At most, it shows that he was attracted to young women above the age of consent, which is neither a crime nor evidence of a crime. The Court recognized this distinction at the November 1 conference in the discussion of Accuser-3's evidence:\nMS. MOE: ... I think as a matter of common sense, a jury understanding that the defendant is willing to provide Epstein with a girl at the age of 17 would certainly speak to her knowledge of his sexual preferences.\nTHE COURT: Why doesn't it speak to a knowledge of sexual preferences to someone just above the age of consent?\n2049808.1\nDOJ-OGR-00007440",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 4 of 12",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nNovember 11, 2021\nPage 4",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Hence, even if we assume for the sake of argument that everything Accuser-3 told the government is true (which we do not concede), her testimony would not in any way establish that \"minors who gave sexualized massages to Epstein were compensated.\" Accuser-3, quite simply, was not under the age of eighteen and was therefore not a minor (under any relevant federal or state statute) when she allegedly . Second, as a factual matter, the government is talking out of both sides of its mouth. The government cannot offer Accuser-3's testimony as proof of a sex trafficking conspiracy when Accuser-3's own statements therefore eliminate any basis for the admission of her testimony as direct evidence of Count Five.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "As to the issue of Epstein's sexual attraction to young women, the government is once again impermissibly attempting to use an example of entirely legal conduct as proof of a conspiracy to engage in illegal conduct. Accuser-3's evidence does not show that Epstein was attracted to underage girls. At most, it shows that he was attracted to young women above the age of consent, which is neither a crime nor evidence of a crime. The Court recognized this distinction at the November 1 conference in the discussion of Accuser-3's evidence:",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "MS. MOE: ... I think as a matter of common sense, a jury understanding that the defendant is willing to provide Epstein with a girl at the age of 17 would certainly speak to her knowledge of his sexual preferences.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "THE COURT: Why doesn't it speak to a knowledge of sexual preferences to someone just above the age of consent?",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "2049808.1\nDOJ-OGR-00007440",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Epstein",
+      "Accuser-3",
+      "MS. MOE"
+    ],
+    "organizations": [],
+    "locations": [],
+    "dates": [
+      "November 11, 2021",
+      "November 1",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "494",
+      "2049808.1",
+      "DOJ-OGR-00007440"
+    ]
+  },
+  "additional_notes": "The document appears to be a court transcript or legal filing related to the case of Epstein. There are redactions in the text, indicating sensitive or protected information."
+}

results/IMAGES003/DOJ-OGR-00007442.json

@@ -0,0 +1,77 @@
+{
+  "document_metadata": {
+    "page_number": "6",
+    "document_number": "494",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 6 of 12\nThe Honorable Alison J. Nathan\nNovember 11, 2021\nPage 6\nRule 404(b) and should be excluded. See Fed. R. Evid. 404(b)(1) (“Evidence of any other crime, wrong, or act is not admissible to prove a person’s character in order to show that on a particular occasion the person acted in accordance with the character.”); see also United States v. Curley, 639 F.3d 50, 57 (2d Cir. 2011) (Rule 404(b) evidence “serves a proper purpose so long as it is not offered to show the defendant’s propensity to commit the offense”).\nThe government has been completely candid that its primary purpose for introducing Accuser-3’s evidence is to show Epstein’s alleged “sexual preference” for young girls and Ms. Maxwell’s purported knowledge of his sexual preference. In support of its argument, the government has frequently pointed to a particular anecdote in Accuser-3’s testimony in which she claims that\n\nBut this anecdote highlights why admitting Accuser-3’s testimony for this purpose is both logically flawed and legally impermissible.1\nFirst, as a factual matter, this testimony does not show Epstein’s “sexual preference” for underaged girls or Ms. Maxwell’s knowledge of that alleged preference.\n\n1 To be clear, the admissibility of Accuser-3’s testimony about is a separate topic that has been separately briefed and argued. We discuss this anecdote here to refute the admissibility of Accuser-3’s testimony to prove Epstein’s alleged “sexual preference” for young girls.\n2049808.1 DOJ-OGR-00007442",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 6 of 12",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nNovember 11, 2021\nPage 6",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "Rule 404(b) and should be excluded. See Fed. R. Evid. 404(b)(1) (“Evidence of any other crime, wrong, or act is not admissible to prove a person’s character in order to show that on a particular occasion the person acted in accordance with the character.”); see also United States v. Curley, 639 F.3d 50, 57 (2d Cir. 2011) (Rule 404(b) evidence “serves a proper purpose so long as it is not offered to show the defendant’s propensity to commit the offense”).",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The government has been completely candid that its primary purpose for introducing Accuser-3’s evidence is to show Epstein’s alleged “sexual preference” for young girls and Ms. Maxwell’s purported knowledge of his sexual preference. In support of its argument, the government has frequently pointed to a particular anecdote in Accuser-3’s testimony in which she claims that",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "But this anecdote highlights why admitting Accuser-3’s testimony for this purpose is both logically flawed and legally impermissible.1",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "First, as a factual matter, this testimony does not show Epstein’s “sexual preference” for underaged girls or Ms. Maxwell’s knowledge of that alleged preference.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1 To be clear, the admissibility of Accuser-3’s testimony about is a separate topic that has been separately briefed and argued. We discuss this anecdote here to refute the admissibility of Accuser-3’s testimony to prove Epstein’s alleged “sexual preference” for young girls.",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "2049808.1 DOJ-OGR-00007442",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Epstein",
+      "Maxwell",
+      "Accuser-3",
+      "Curley"
+    ],
+    "organizations": [
+      "United States"
+    ],
+    "locations": [],
+    "dates": [
+      "November 11, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 494",
+      "2049808.1",
+      "DOJ-OGR-00007442"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly printed, with no visible handwriting or stamps."
+}

results/IMAGES003/DOJ-OGR-00007447.json

@@ -0,0 +1,105 @@
+{
+  "document_metadata": {
+    "page_number": "11",
+    "document_number": "494",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 11 of 12\n\nThe Honorable Alison J. Nathan\nNovember 11, 2021\nPage 11\n\nconsent. The defense proposes the following instruction, which is modeled on the proposed instruction for Accuser-3:\n\nYou have heard testimony from this witness about sexual activity between her and Jeffrey Epstein that occurred [choose all that apply: in Florida when she was above the age of 18; in the U.S. Virgin Islands when she was above the age of 18; in New York when she was above the age of 17; in New Mexico when she was above the age of 16; in the United Kingdom when she was above the age of 16].\n\nFor the purposes of your deliberations, I instruct you that at all times relevant to this case the legal age of consent for sexual activity [choose all that apply: in Florida was 18 years old; in the U.S. Virgin Islands was 18 years old; in New York was 17 years old; in New Mexico was 16 years old; in the United Kingdom was 16 years old].\n\nIf you find that the witness engaged in sexual activity after she was above the relevant age of consent, I instruct you that any such sexual activity was lawful and cannot be considered \"illegal\" or \"criminal\" or \"unlawful\" for purposes of the crimes charged in the indictment.\n\nIV. Accuser-3 Cannot Be Considered a \"Victim\" for Any Legal Purpose\n\nThe Court ruled at the November 10th hearing that Accuser-3 could not be considered a \"victim\" of the crimes charged in the S2 Indictment and that the government should not refer to her as a \"victim\" or a \"minor.\" Accordingly, there is no need for the defense to respond to the government's November 7th Letter.\n\nRespectfully submitted,\n\n/s/ Christian Everdell\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\n\n2049808.1\nDOJ-OGR-00007447",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 11 of 12",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nNovember 11, 2021\nPage 11",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "consent. The defense proposes the following instruction, which is modeled on the proposed instruction for Accuser-3:",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "You have heard testimony from this witness about sexual activity between her and Jeffrey Epstein that occurred [choose all that apply: in Florida when she was above the age of 18; in the U.S. Virgin Islands when she was above the age of 18; in New York when she was above the age of 17; in New Mexico when she was above the age of 16; in the United Kingdom when she was above the age of 16].",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "For the purposes of your deliberations, I instruct you that at all times relevant to this case the legal age of consent for sexual activity [choose all that apply: in Florida was 18 years old; in the U.S. Virgin Islands was 18 years old; in New York was 17 years old; in New Mexico was 16 years old; in the United Kingdom was 16 years old].",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "If you find that the witness engaged in sexual activity after she was above the relevant age of consent, I instruct you that any such sexual activity was lawful and cannot be considered \"illegal\" or \"criminal\" or \"unlawful\" for purposes of the crimes charged in the indictment.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "IV. Accuser-3 Cannot Be Considered a \"Victim\" for Any Legal Purpose",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The Court ruled at the November 10th hearing that Accuser-3 could not be considered a \"victim\" of the crimes charged in the S2 Indictment and that the government should not refer to her as a \"victim\" or a \"minor.\" Accordingly, there is no need for the defense to respond to the government's November 7th Letter.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Respectfully submitted,",
+      "position": "body"
+    },
+    {
+      "type": "signature",
+      "content": "/s/ Christian Everdell",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "Christian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "2049808.1\nDOJ-OGR-00007447",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan",
+      "Jeffrey Epstein",
+      "Christian Everdell",
+      "Christian R. Everdell"
+    ],
+    "organizations": [
+      "COHEN & GRESSER LLP"
+    ],
+    "locations": [
+      "Florida",
+      "U.S. Virgin Islands",
+      "New York",
+      "New Mexico",
+      "United Kingdom"
+    ],
+    "dates": [
+      "November 11, 2021",
+      "November 10th",
+      "November 7th",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 494",
+      "S2 Indictment",
+      "2049808.1",
+      "DOJ-OGR-00007447"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. The text is mostly printed, with a signature at the end. There are no visible stamps or handwritten annotations."
+}

results/IMAGES003/DOJ-OGR-00007448.json

@@ -0,0 +1,58 @@
+{
+  "document_metadata": {
+    "page_number": "12",
+    "document_number": "494",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": false,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 12 of 12\nThe Honorable Alison J. Nathan\nNovember 11, 2021\nPage 12\nNew York, New York 10022\n(212) 957-7600\ncc: All Counsel of Record (By ECF)\n2049808.1 DOJ-OGR-00007448",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 12 of 12",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "The Honorable Alison J. Nathan\nNovember 11, 2021\nPage 12",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "New York, New York 10022\n(212) 957-7600",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "cc: All Counsel of Record (By ECF)",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "2049808.1 DOJ-OGR-00007448",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan"
+    ],
+    "organizations": [],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 11, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "494",
+      "2049808.1",
+      "DOJ-OGR-00007448"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007449.json

@@ -0,0 +1,86 @@
+{
+  "document_metadata": {
+    "page_number": "1",
+    "document_number": "495",
+    "date": "11/22/21",
+    "document_type": "Court Order",
+    "has_handwriting": false,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 495 Filed 11/22/21 Page 1 of 2\nUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK\nUnited States of America,\n-v-\nGhislain Maxwell,\nDefendant.\nALISON J. NATHAN, District Judge:\nOn November 1, 2021, the Defense noticed eight expert witnesses. Dkt. No. 418-1. On November 15, 2021, the Government filed a motion to preclude the testimony of six of the experts. See id. The Defense filed a response on November 19, 2021, and the Government filed a motion for leave to file a reply on November 22, 2021.1 The moving papers have been filed temporarily under seal to permit the parties the opportunity to propose sealing or limited redactions in accordance with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).\nIn two Memorandum Opinions and Orders temporarily filed under seal, the Court GRANTS the Government's motion to preclude as to Dr. Ryan Hall's testimony and GRANTS the Government's motion to preclude as to Bennett Gershman's testimony.\nThe Court will send the temporarily sealed Memorandum Opinions and Orders to the parties. By November 24, 2021, the parties are ORDERED to inform the Court whether either seeks sealing or limited redactions of the Memorandum Opinions and Orders, justifying any such request by reference to the three-part test articulated by the Second Circuit in Lugosch v.\n1 The Court denies the Government's request to file a reply because the Government's motion to preclude and the Defendant's response are sufficient for this Court to rule on the motion.\n1\nDOJ-OGR-00007449",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 495 Filed 11/22/21 Page 1 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "United States of America,\n-v-\nGhislain Maxwell,\nDefendant.",
+      "position": "top"
+    },
+    {
+      "type": "stamp",
+      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: _____ DATE FILED: 11/22/21",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "20-CR-330 (AJN)\nORDER",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN, District Judge: ...",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "1 The Court denies the Government's request to file a reply because the Government's motion to preclude and the Defendant's response are sufficient for this Court to rule on the motion.",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "1\nDOJ-OGR-00007449",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislain Maxwell",
+      "Alison J. Nathan",
+      "Dr. Ryan Hall",
+      "Bennett Gershman"
+    ],
+    "organizations": [
+      "United States District Court",
+      "Southern District of New York",
+      "Second Circuit"
+    ],
+    "locations": [
+      "New York",
+      "Onondaga"
+    ],
+    "dates": [
+      "November 1, 2021",
+      "November 15, 2021",
+      "November 19, 2021",
+      "November 22, 2021",
+      "November 24, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 495",
+      "Dkt. No. 418-1",
+      "20-CR-330 (AJN)",
+      "DOJ-OGR-00007449"
+    ]
+  },
+  "additional_notes": "The document is a court order from the United States District Court for the Southern District of New York. It appears to be a formal, typed document with a stamp indicating electronic filing. There are no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007450.json

@@ -0,0 +1,72 @@
+{
+  "document_metadata": {
+    "page_number": "2 of 2",
+    "document_number": "495",
+    "date": "11/22/21",
+    "document_type": "court document",
+    "has_handwriting": true,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 495 Filed 11/22/21 Page 2 of 2 Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). In addition, by that date, the parties are FURTHER ORDERED to file any proposed redactions to the moving papers and/or supporting exhibits on the public docket, again justifying any such request by reference to the Lugosch test. SO ORDERED. Dated: November 22, 2021 New York, New York ALISON J. NATHAN United States District Judge",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 495 Filed 11/22/21 Page 2 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). In addition, by that date, the parties are FURTHER ORDERED to file any proposed redactions to the moving papers and/or supporting exhibits on the public docket, again justifying any such request by reference to the Lugosch test.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "SO ORDERED.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November 22, 2021 New York, New York",
+      "position": "middle"
+    },
+    {
+      "type": "signature",
+      "content": "",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN United States District Judge",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "2",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007450",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "ALISON J. NATHAN"
+    ],
+    "organizations": [],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 22, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 495",
+      "DOJ-OGR-00007450"
+    ]
+  },
+  "additional_notes": "The document appears to be a court order with a signature from a judge. The text is mostly printed, with a handwritten signature. There are no visible stamps or redactions."
+}

results/IMAGES003/DOJ-OGR-00007451.json

@@ -0,0 +1,90 @@
+{
+  "document_metadata": {
+    "page_number": "1 of 2",
+    "document_number": "496",
+    "date": "11/22/21",
+    "document_type": "Court Order",
+    "has_handwriting": false,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 496 Filed 11/22/21 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, -v- Ghislaine Maxwell, Defendant. ALISON J. NATHAN, District Judge: The Court is in receipt of the Government's, Administrator Feldman's, and two anticipated witnesses' motions to quash the Defendant's Rule 17(c)(3) subpoena. Dkt. No. 486. The motions to quash are DENIED.1 The Court hereby ORDERS the Administrator of the Epstein Victims' Compensation Program to produce to the Court via electronic thumb drive any materials responsive to the subpoena as soon as possible, but no later than 12:00 p.m. on November 24, 2021. Upon receipt, the Court will determine whether the parties may \"inspect all or part\" of the materials. Fed. R. Crim. P. 17(c)(1). In that event, the Court may determine that an appropriate protective order is necessary for the parties' review of some or all of the materials. Review under a protective order may better facilitate the review process of the narrow, specific, and targeted materials and may better ensure no trial delay, as compared to a review process solely by the Court. Accordingly, the parties shall negotiate a protective order and submit the proposal for approval by the Court no later than 12:00 p.m. on November 24, 2021. SO ORDERED. 1 Administrator Feldman's request for oral argument is accordingly denied. 1 DOJ-OGR-00007451",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 496 Filed 11/22/21 Page 1 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "United States of America, -v- Ghislaine Maxwell, Defendant.",
+      "position": "top"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN, District Judge:",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Court is in receipt of the Government's, Administrator Feldman's, and two anticipated witnesses' motions to quash the Defendant's Rule 17(c)(3) subpoena. Dkt. No. 486. The motions to quash are DENIED.1",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "The Court hereby ORDERS the Administrator of the Epstein Victims' Compensation Program to produce to the Court via electronic thumb drive any materials responsive to the subpoena as soon as possible, but no later than 12:00 p.m. on November 24, 2021.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "Upon receipt, the Court will determine whether the parties may \"inspect all or part\" of the materials. Fed. R. Crim. P. 17(c)(1). In that event, the Court may determine that an appropriate protective order is necessary for the parties' review of some or all of the materials. Review under a protective order may better facilitate the review process of the narrow, specific, and targeted materials and may better ensure no trial delay, as compared to a review process solely by the Court. Accordingly, the parties shall negotiate a protective order and submit the proposal for approval by the Court no later than 12:00 p.m. on November 24, 2021.",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "SO ORDERED.",
+      "position": "bottom"
+    },
+    {
+      "type": "printed",
+      "content": "1 Administrator Feldman's request for oral argument is accordingly denied.",
+      "position": "footer"
+    },
+    {
+      "type": "stamp",
+      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC#: DATE FILED: 11/22/21",
+      "position": "margin"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislaine Maxwell",
+      "Alison J. Nathan",
+      "Administrator Feldman"
+    ],
+    "organizations": [
+      "United States District Court",
+      "Southern District of New York",
+      "Epstein Victims' Compensation Program"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "11/22/21",
+      "November 24, 2021"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 496",
+      "Dkt. No. 486",
+      "20-CR-330 (AJN)",
+      "DOJ-OGR-00007451"
+    ]
+  },
+  "additional_notes": "The document is a court order from the United States District Court for the Southern District of New York. It appears to be a formal and official document, with no visible redactions or damage."
+}

results/IMAGES003/DOJ-OGR-00007452.json

@@ -0,0 +1,64 @@
+{
+  "document_metadata": {
+    "page_number": "2",
+    "document_number": "496",
+    "date": "November 22, 2021",
+    "document_type": "Court Document",
+    "has_handwriting": true,
+    "has_stamps": false
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 496 Filed 11/22/21 Page 2 of 2\nDated: November 22, 2021 New York, New York\nALISON J. NATHAN United States District Judge",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 496 Filed 11/22/21 Page 2 of 2",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November 22, 2021 New York, New York",
+      "position": "left"
+    },
+    {
+      "type": "handwritten",
+      "content": "Alison J. Nathan",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN United States District Judge",
+      "position": "middle"
+    },
+    {
+      "type": "printed",
+      "content": "2",
+      "position": "footer"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007452",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Alison J. Nathan"
+    ],
+    "organizations": [
+      "United States District Court"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 22, 2021",
+      "11/22/21"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "496",
+      "DOJ-OGR-00007452"
+    ]
+  },
+  "additional_notes": "The document appears to be a court filing with a signature from a United States District Judge. The document is dated November 22, 2021, and is related to case number 1:20-cr-00330-PAE."
+}

results/IMAGES003/DOJ-OGR-00007453.json

@@ -0,0 +1,98 @@
+{
+  "document_metadata": {
+    "page_number": "1 of 11",
+    "document_number": "497",
+    "date": "11/23/21",
+    "document_type": "Court Order",
+    "has_handwriting": true,
+    "has_stamps": true
+  },
+  "full_text": "Case 1:20-cr-00330-PAE Document 497 Filed 11/23/21 Page 1 of 11\nUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK\nUnited States of America,\n-v-\nGhislainc Maxwell,\nDefendant.\nALISON J. NATHAN, District Judge:\nAs discussed at today's conference, attached is the Court's draft preliminary instructions for the sworn jury. The Court has considered both parties' proposed instructions as to the Court's order that certain witnesses be permitted to testify or be referred to by first name only or pseudonym. Dkt. No. 432. The draft preliminary instructions include a limiting instruction regarding this process.\nThe parties may suggest any proposed edits to the preliminary instructions by letter on or before November 27, 2021, or they shall indicate by that date that they have no objections or suggestions.\nSO ORDERED.\nDated: November 23, 2021 New York, New York\nALISON J. NATHAN United States District Judge\nDOJ-OGR-00007453",
+  "text_blocks": [
+    {
+      "type": "printed",
+      "content": "Case 1:20-cr-00330-PAE Document 497 Filed 11/23/21 Page 1 of 11",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "United States of America, -v- Ghislainc Maxwell, Defendant.",
+      "position": "header"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN, District Judge:",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "As discussed at today's conference, attached is the Court's draft preliminary instructions for the sworn jury. The Court has considered both parties' proposed instructions as to the Court's order that certain witnesses be permitted to testify or be referred to by first name only or pseudonym. Dkt. No. 432. The draft preliminary instructions include a limiting instruction regarding this process.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "The parties may suggest any proposed edits to the preliminary instructions by letter on or before November 27, 2021, or they shall indicate by that date that they have no objections or suggestions.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "SO ORDERED.",
+      "position": "body"
+    },
+    {
+      "type": "printed",
+      "content": "Dated: November 23, 2021 New York, New York",
+      "position": "footer"
+    },
+    {
+      "type": "handwritten",
+      "content": "Alison J. Nathan",
+      "position": "signature"
+    },
+    {
+      "type": "printed",
+      "content": "ALISON J. NATHAN United States District Judge",
+      "position": "footer"
+    },
+    {
+      "type": "stamp",
+      "content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 11/23/21",
+      "position": "margin"
+    },
+    {
+      "type": "printed",
+      "content": "DOJ-OGR-00007453",
+      "position": "footer"
+    }
+  ],
+  "entities": {
+    "people": [
+      "Ghislainc Maxwell",
+      "Alison J. Nathan"
+    ],
+    "organizations": [
+      "United States District Court",
+      "United States of America"
+    ],
+    "locations": [
+      "New York"
+    ],
+    "dates": [
+      "November 23, 2021",
+      "November 27, 2021"
+    ],
+    "reference_numbers": [
+      "1:20-cr-00330-PAE",
+      "Document 497",
+      "Dkt. No. 432",
+      "20-CR-330 (AJN)",
+      "DOJ-OGR-00007453"
+    ]
+  },
+  "additional_notes": "The document is a court order from the United States District Court for the Southern District of New York. It is signed by Judge Alison J. Nathan and includes a stamp indicating that it was electronically filed on November 23, 2021."
+}